Taking and Defending Depositions

162 essential rules admission answer appropriate attorney Cheatham claims or defenses client Coaching Collinson complaint conference court reporter cross-examination Defending counsel depo deponent's deposed deposition testimony deposition transcript discovery plan discussed document requests everything evidence Examining counsel exhibits expert Explain facts going hearsay identify impeachment initial disclosures inquiry interrogatory judge lawyer leading questions limit litigation March 13 matter memo memory memory bias ment Milburn motion to compel MRPC necessary ness non-party deponent notice oath objections offers of proof Okay opponent opposing party Party admissions party's person plaintiff preparation privilege produce protective order Ralph Seymour Rambo reasonable record remember response Rule 30 Rule 34 side's sition stipulation subpoena summary judgment taking depositions talk tell testify theory things tion Transcript awareness trial truth understand unless witness witness's