E-Discovery LLC

JULY 31, 2025

In pertinent part, Herman objected to the definitions in Payne’s interrogatories. This Court has also stated that unreasonable definitions may render interrogatories so burdensome that objections to the entire series should be sustained, with sanctions. 2d Depositions and Discovery § 125. Diversified Products Corp. Union Pac.

Interrogatories

E-Discovery LLC

JUNE 18, 2025

The 1983 Advisory Committee Note to Rule 26(g) states: “The subdivision provides a deterrent to both excessive discovery and evasion by imposing a certification requirement that obliges each attorney to stop and think about the legitimacy of a discovery request, a response thereto, or an objection.” Lewis and Zappala.

Discovery

E-Discovery LLC

JULY 26, 2025

After several extensions of time and meet-and-confers, defendants responded with only objections. The court wrote: “The Court did not grant the request for a Rule 30(b)(6) deposition but warned Defendants that that relief would be on the table if the declaration was not adequate to the task.” Plaintiffs served a document request.

Discovery

E-Discovery LLC

JULY 6, 2025

Sidley moved to compel production of documents by a third party law firm, Smith, Gambrell & Russell LLP (“SGR”) and also “deposition testimony concerning the Cácereses’ communications with their attorneys about their potential claims against Sidley, including facts supporting such claims, which Plaintiffs and SGR have asserted are privileged.”

Interrogatories

Steno

JANUARY 6, 2025

Executive Summary Challenge: After decades of litigation experience, attorney Mike Marzban recognized that colleagues were often too shy to provide candid feedback on his deposition technique. He needed an objective way to evaluate his performance and identify potential blind spots in his questioning strategies.

Depositions

E-Discovery LLC

JULY 20, 2025

Vasquez, Blake Lively’s Deposition Pushed Back by 2 Weeks After Judge’s Latest Ruling in Justin Baldoni Case (Jul. Lively objected and wrote: “Subject to and without waiving the foregoing objections, and only after the entry of a mutually agreed upon ESI protocol, Ms. 14, 2025); I. 14, 2025); E. 19, 2025); B. 354, 359 (D.

Interrogatories

E-Discovery LLC

JULY 30, 2025

It appears from the docket that on July 21, 2025, Genesh filed an objection to the Magistrate Judge’s order on this issue. The court strikes all references to those documents from the deposition records and prohibits the parties from referencing the documents or their contents in future depositions or trial testimony in this case.

Discovery

E-Discovery LLC

JULY 23, 2025

22, 2023); Court Uses an Informal Discovery Procedure to Hold That Untimely Objections Were Waived, and Answers to Interrogatories Defectively Referred to Deposition (Nov. Procedures to Avoid, and Promptly Resolve, Discovery Disputes in the District of Maryland (Dec. 15, 2025). [2] 15, 2025). [2]

Discovery

E-Discovery LLC

JULY 22, 2025

The memorandum states that this stay of approximately two days is much less than the Fourth Circuit’s stay of 14-days that has been in effect for years, without objection, citing Standing Ord. In another, the Court extended the stay, without objection by the Government. 19-01 (4 th Cir.

Cross-Complaint

Practice of Law

JUNE 17, 2025

With any luck for NCAA athletes, the massive keggers haven't gotten past the planning stage, and nobody has gone to the dealership to put down a deposit on a Lamborghini in their school's colors yet. Since they filed objections to the settlement, they were determined to have standing for the appeal. Briefs are due by October 3, 2025.

Education

Lawmatics

MARCH 1, 2023

The rules surrounding depositions can be enough to send new lawyers into a cold sweat. Depositions are a critical tool for building a case, and as such, it is essential for attorneys of all skill levels to be well-versed in the various objections that can arise during the course of a deposition.

Depositions

Attorney at Work

MAY 28, 2022

From time to time, opposing counsel may act in an uncivil or unprofessional manner during a telephone call, where there is no official record as there might be in a deposition or a written communication. Objectively summarize what was said, making sure to include the uncivil behavior. During a Deposition. On the Phone.

Depositions

E-Discovery LLC

OCTOBER 22, 2024

DILATORY AND UNPERSUASIVE CHALLENGE TO DEPOSITION NOTICE “The Court need not resolve the factual skirmish over whether Washington agreed to the topics in NNI’s Rule 30(b)(6) notice to resolve the motion. The State’s newly-minted objections to the deposition topics come far too late , and are not persuasive.” emphasis added).

Objections

WA Bar News

NOVEMBER 12, 2024

1 The amendments to CR 26 affect objections, supplementation, and disclosure of experts. 1, 2024, codify procedure for depositions by remote means. In response to the objection this might increase costs and introduce ambiguity, the Work Group determined most parties already ask for supplementation, so there is no net increase in work.

Depositions

E-Discovery LLC

MAY 20, 2025

May 5, 2025), addressed the important issue of apex depositions in the governmental context. Plaintiffs, a parent and a school-age minor, in a personal injury claim against a school system sought the depositions of nine high-ranking government employees. May 19, 2025)(deposition of CFO and Senior V.P. of private entity).

Depositions

WA Bar News

JUNE 11, 2024

In this column, we’ll address a narrower, but more common, subset of deposition misconduct that the ABA opinion touches on: improper “coaching” during depositions and improper objections intended to impede the questioner. 10 Second, we’ll focus on depositions rather than hearings or trials. Washington RPC 4.4(a)

Depositions

Plaintiff Trial Lawyer Tips

JUNE 27, 2024

There are a volume of available ideas and outlines for the discovery deposition of a medical malpractice expert including advice to not take the deposition at all in some circumstances. FULL DETAILS 5 HOW MANY PAST DEPOSITIONS GIVEN? CHARGE PER HOUR a. PREPARATION WORK b. DEPOSITION TIME c. TRIAL 2.

Depositions

E-Discovery LLC

NOVEMBER 27, 2024

They produced documents and a privilege log, but objected to a deposition. OLPC moved to compel a deposition and for additional documents or an updated privilege log. That motion was granted in part, with the court ordering the law firm to produce documents or an adequate privilege log and compelling the deposition.

Subpoenas

E-Discovery LLC

AUGUST 16, 2024

The identification of non-custodial sources of data is a foundational issue, and you don’t get to make an objection to the other side’s disclosure and then hold on to that objection forever and ever, and years later ask to start the whole process over from scratch. We’re not starting this over from the beginning.

Discovery

E-Discovery LLC

OCTOBER 17, 2024

They also sought the former attorney’s deposition regarding the alleged offer. When it came to the request for a deposition , the court wrote: Lastly, Plaintiffs request a deposition of former Town Attorney Nugent in connection with his role in making the alleged quid pro quo as outlined in Plaintiffs’ motion papers.

Discovery

E-Discovery LLC

APRIL 18, 2025

Defendant contends this document dump served no other purpose than to obstruct MJCs review process … and impede [its] ability to prepare for … deposition scheduled April 4th. Rule 34(b)(2)(D) states that: The response may state an objection to a requested form for producing electronically stored information.

Objections

The Cloud Court Blog

OCTOBER 26, 2022

Over the years I’ve attended a lot of depositions. When the deposition is over, the people that were in the room often have a sort of inexplicable, Venn-type diagram of disparate recollections about what actually happened. But now, as my team has continued to study depositions, I've come to suspect that something else is at play here.

Depositions

E-Discovery LLC

MAY 31, 2024

Here, the burdens associated with the proposed discovery, including re-doing liability expert reports and depositions, are heavy; and the likely benefits, given the elapsed deadlines, are nil. 1, 2023)( untimely discovery objection was waived); cf. The court will deny Fiskars’ motion for this reason alone.

Discovery

E-Discovery LLC

MARCH 8, 2025

The court wrote that it then adopted Defendants protocol [as an order] and no objection to that order was filed. See Too Busy to Respond to Discovery = Waiver of Objections & Sanctions (Nov. Mistake #3: On January 2, 2025, [1] Plaintiff objected to the Magistrate Judges December 23, 2024, decision. [2] See 28 U.S.C.636(b)(1)(fourteen

Discovery

E-Discovery LLC

DECEMBER 19, 2024

Plaintiffs later noted the deposition of a non-party, Dr. Fanning on March 29, 2024. Objections were due by July 10 th. Fanning and well before the deposition. Plaintiffs contended that SCA did nothingsuch as objecting or filing a motion to quashsince it received notice of the Subpoena.

Depositions

E-Discovery LLC

APRIL 15, 2025

Defendant contends this document dump served no other purpose than to obstruct MJCs review process … and impede [its] ability to prepare for … deposition scheduled April 4th. Rule 34(b)(2)(D) states that: The response may state an objection to a requested form for producing electronically stored information.

Discovery

E-Discovery LLC

DECEMBER 16, 2024

Etame did not appear for his deposition on March 10, 2022. Nguhs motions, but held the sanctions motion in abeyance, and ordered Mr. Etame to appear for deposition. After the parties discussed scheduling, Mr. Etame failed to appear for deposition. As a result, Ms. Nguh filed a motion for sanctions for his failure to appear.

Discovery

Planet Depos

OCTOBER 30, 2024

It is the very reason you hire a court reporter for your deposition. Each participant in the deposition can aid in reaching the goal of a timely, accurate transcript. Each participant in the deposition can aid in reaching the goal of a timely, accurate transcript. Every court reporter works efficiently toward this goal.

Depositions

E-Discovery LLC

AUGUST 13, 2024

Next, the undersigned specifically directed the parties to identify a timetable for completion of all discovery, including taking any depositions. ( Regarding depositions, the undersigned cautioned Plaintiff that if she wanted to take any depositions, she was to communicate with the Defendant’s counsel about the same. (

Discovery

E-Discovery LLC

MAY 30, 2024

PNI objected to discovery in part by asserting several privileges. After document was used in a deposition, PNI sought a “clawback” under the ESI Protocol. Moreover, the delay prejudices Resolve as it attempts to complete depositions and other discovery without the benefit of documents to which it may be entitled. 565, 577 (D.

Discovery

Attorney at Work

SEPTEMBER 15, 2022

Offering a legal service is, of course, quite different from developing a new disinfectant, or building a software application or a material object. They can also monitor accepted settlements, tracking any pending payments, recording any deposited checks, and projecting any future income streams. A Powerful Project Management Panacea?

Trial Preparation

E-Discovery LLC

JANUARY 27, 2025

A dispute arose over the application of the ESI Order and: Meta wants to clarify that the requesting partys opportunity to object to the sufficiency of the producing partys original and new search terms is triggered only if the producing party identified responsive documents in the null set sample.

Discovery

E-Discovery LLC

AUGUST 31, 2024

These videos were admitted into evidence without objection and were contained in about 30 video exhibits. Over objection, Lieutenant McDonald testified that he focused on one of the suspects who wore distinctive attire. The court admitted the composite video over objection. before the shooting; on Pleasant Street at 12:17 a.m.

Admissibility

E-Discovery LLC

JANUARY 15, 2025

Plaintiffs asserted, however, that Defendant insists on keeping its relevant custodians and data sources to itself (or at least forcing Plaintiffs to try and discover the same through interrogatories and depositions). emphasis added]. The Zarfati court then published an ESI Protocol. at *5, passim.

Discovery

E-Discovery LLC

JANUARY 8, 2025

Reliance on Rule 33(d) is appropriate when the interrogatory requests objective facts that are obvious from the specified documents, but is generally inappropriate when the interrogatory asks a party to state its contentions or to state facts supporting its allegations.

Interrogatories

Plaintiff Trial Lawyer Tips

JANUARY 15, 2025

They just launch off without any particular objective other than an impeachment they have available. We need specific focused objectives thought out and planned in advance. My cases involve depositions that are all video taped. You can show excerpts from the expert deposition video if available. Apply Psycho Drama.

Cross-Examination

E-Discovery LLC

APRIL 10, 2025

In my opinion, one factor that should be considered in these discussions is how the produced communications can be used in depositions, motions, and at trial. The adverse party may do so over a hearsay objection. In each instance, one may reasonably ask what is the document? Fed.R.Evid.

Discovery