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Remote Depositions Federal Rules of Civil Procedure

Esquire Deposition Solutions, LLC

The Apex Doctrine and Remote Depositions

The apex deposition doctrine is a judge-made rule that protects company executives from harassing, repetitive depositions in cases in which the executive has little relevant evidence to provide. Courts applying the doctrine...more

Esquire Deposition Solutions, LLC

New Minnesota Rule Removes Roadblocks to Remote Depositions

Revised Minnesota pretrial discovery rules, which took effect Jan. 1, now encourage remote depositions by allowing them to be set by notice alone. Former practice required either a court order or stipulation....more

Esquire Deposition Solutions, LLC

Citing Wildfire Threat, Court Says Attorney Need Not Travel for In-Person Deposition

The devastating wildfires that raced through southern California these past few weeks caused loss of life, property damage in the billions of dollars, and upheaval in the lives of millions of Americans who live in that...more

Esquire Deposition Solutions, LLC

When Mere Objections Are Not Enough

It’s a common practice during a deposition for lawyers to assert legal objections to witness testimony but then allow the deposition to proceed. In fact, this practice is broadly encouraged. Depositions are wide-ranging...more

Esquire Deposition Solutions, LLC

Washington Revises Rules for Remote Depositions

The Washington Supreme Court recently approved significant revisions to that state’s procedural rules on remote depositions. Revised Rule 30 of the Washington Civil Rules will now allow remote depositions to be noticed...more

Esquire Deposition Solutions, LLC

Deposition in Hand, Party Need Not Testify at Trial

Are personal injury plaintiffs legally required to testify at their trials? Actually, not. Under the right circumstances, deposition testimony can be used in lieu of live trial testimony if the trial court finds that the...more

Esquire Deposition Solutions, LLC

Poor Health, Family Obligations Supply Good Cause for Avoiding Deposition Travel

To their credit, experienced litigators are able to resolve the vast majority of pretrial discovery disputes without the need for court intervention. This is particularly true when the dispute in question is whether a...more

Butler Snow LLP

Subpoenaed Remote Testimony from Anywhere and Everywhere? Ninth Circuit Says No.

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With the COVID pandemic, remote video depositions and trial testimony very quickly went from rare to routine. Remote testimony, for the most part, is viewed as a convenience to both witnesses and attorneys, and parties and...more

U.S. Legal Support

Exploring Different Types of Depositions

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Though typically conducted in a conference room, a deposition can take place in many locations and through a variety of methods. So long as you capture a verbatim record, either face-to-face or remotely through the use of...more

Esquire Deposition Solutions, LLC

Taxation of Deposition-Related Costs in Federal Courts

As litigators know, the United States follows the so-called “American Rule” when apportioning the costs of litigation. Unless a statute specifically provides otherwise, parties in court are responsible for their own...more

Esquire Deposition Solutions, LLC

Federal Litigants Can’t Insist on In-Person Depositions

Way back in April 2020, during the early days of the COVID-19 pandemic, a federal magistrate judge in Colorado had already seen enough to offer the following plea that lawyers reassess their habit of traveling long distances...more

Conn Kavanaugh

Improper Coaching in Remote Depositions

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“He’s going to tell the truth. The truth is very, you know, complicated. So we went over it carefully, and just not to leave anything up to chance . . . . or Michael’s judgment.” Fans of the NBC sitcom, the Office, might...more

Esquire Deposition Solutions, LLC

Availability of Remote Depositions May Pressure Expert Travel Expenses

Reasonable expenses for an expert witness deposition surely include the expert’s travel time, airfare and hotel accommodations. Right? It’s true that litigators are free to make their own financial arrangements regarding the...more

Esquire Deposition Solutions, LLC

Court Ruling Shows (Again) How Depositions Save Money in Litigation

The international law firm McGuire Woods recently published a news note, Virginia Court Holds School Board Immune From Virginia Human Rights Act Claims, explaining how a local school board successfully raised a sovereign...more

Esquire Deposition Solutions, LLC

The 4 Reasons to Conduct a Deposition

No other pretrial discovery process rivals the deposition for its ability to alter the course of civil litigation. Depositions alone bring litigators face-to-face with key witnesses, experts, and the parties themselves in a...more

Esquire Deposition Solutions, LLC

The Four Types of Depositions

There are four main ways to conduct a pretrial deposition in modern law practice: the deposition by written question, the in-person deposition, the remote deposition, and the hybrid deposition. Each has its strengths and...more

Esquire Deposition Solutions, LLC

Remote Depositions Buoyed by Skilled Litigators and Innovative Technology

When the COVID-19 pandemic struck in 2020, experienced litigators quickly discovered that they would have to adapt and learn to thrive in a new adversarial arena — the computer monitor. And adapt they did....more

Esquire Deposition Solutions, LLC

Are Costs for Stenographic and Video Copies of the Same Deposition Taxable?

Yes absolutely, but with one caveat. Counsel should not overlook the requirement to carefully document the necessity of any costs claimed to be taxable. This includes costs for videotape copies of depositions....more

Esquire Deposition Solutions, LLC

Zoom Isn’t the Place Where Remote Depositions Occur

In the early, heady days of the commercial internet, legal scholars David Johnson and David Post wrote, “because events on the Net occur everywhere but nowhere in particular … no physical jurisdiction has a more compelling...more

Esquire Deposition Solutions, LLC

Who Can Attend a Remote Deposition?

Until very recently, the rule in many jurisdictions was that any individual could attend a deposition unless the trial court ordered otherwise. Some litigators brought expert witnesses to the deposition of the opposing...more

Esquire Deposition Solutions, LLC

62-Hour Trek to Palau or Remote Deposition From Home? You Be the Judge

Palau is an island archipelago in the Pacific Ocean. The local economy depends on tourism, mainly from visitors interested in snorkeling and scuba diving along its beautiful barrier reefs. Tourism aside, the Palau economy is...more

Esquire Deposition Solutions, LLC

Do Remote Depositions From Home Violate Rule 45(c)’s 100-Mile Subpoena Limit?

We recently blogged about a case in which a court ruled that a subpoena for a remote deposition did not violate Federal Rule of Civil Procedure 45(c)’s 100-mile limit on subpoenas for non-party witnesses because the deponent...more

Array

Do Rule 45 Restrictions Apply to Remote Proceedings? Courts Are Split

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The rise of remote proceedings in response to the COVID-19 pandemic has led federal courts to consider novel issues involving the subpoena of individuals for remotely held depositions and hearings. Last year, three federal...more

Benesch

Remote Hearings Are Ill-Suited Default For Litigation Realities

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Much undoubtedly changed in the world of pandemic litigation. From remote proceedings to Zoom depositions to mediation by virtual breakout room, we have grown accustomed to litigation from the living room. But to be...more

Esquire Deposition Solutions, LLC

Remote Depositions Prompt Novel Court Rulings on Discovery Practice

A prior post looked at two recent trial court rulings involving claims that witness coaching had occurred during a remote deposition, making the point that litigators can protect their clients against witness coaching by...more

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