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Remote Depositions Federal Rules of Civil Procedure Discovery

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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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

Esquire Deposition Solutions, LLC

The High Price of Failing to Appear for Deposition

The necessity to advance civil litigation during the COVID-19 pandemic remains a challenge for counsel, even as positivity and death rates are falling across the United States. Litigators are juggling client meetings, court...more

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