Preliminary Sections

• Author: Joseph A. Ranney
• Pages: 1-24

DEPOSITION OBJECTIONS

BY JOSEPH A. RANNEY

HIGHLIGHTS

Deposition Objections gives you dozens of objections and tactics for confronting and resolving contentious deposition

disputes. This edition adds new text, tips, and approximately 100 new cases to help you protect your witness and your

case. Revisions and additions include:

CHAPTER 1  OBJECTING TO DEPOSITION NOTICES AND SUBPOENAS

Proportionality (§§1:80, 1:81):

• In 2015, the Federal Rules of Civil Procedure were amended to require that discovery be proportional to

the needs of the case—which had a major impact on the scope of permissible deposition objections. This

edition describes how courts are applying proportionality and how you can use this new law to make or

oppose objections more effectively.

CHAPTER 4  ATTORNEYCLIENT PRIVILEGE

Who Is an Attorney’s Representative for Purposes of Asserting the Privilege? (§4:20):

• How you can determine whether communications with people who

are assisting you are shielded from discovery by your opponent.

CHAPTER 10  RELEVANCE: PRIVACY PRIVILEGE

Requests for New Documents During a Deposition (§12:14):

• How to respond when your opponent makes a request for your client’s social media records—

important new case law makes it more diff‌icult to object to disclosure of those records.

CHAPTER 17  COACHING AND COMMUNICATIONS WITH THE WITNESS DURING BREAKS

Possible Sanctions for Improperly Talking to a Witness During a Deposition Breaks (§§17:52, 17:53):

• How to turn around improper deposition conferences between

opposing counsel and his client and use them to aid your case at trial.

CHAPTER 22  OBJECTIONS TO VIDEOTAPE AND REMOTE DEPOSITIONS

Remote Depositions Before and After COVID (§§22:20-22:22):

• Remote depositions were rare before the COVID-19 pandemic; now they are essential. This edition explains

how you can arrange remote depositions and use objections at such depositions to protect your client’s interests.

AND MORE!

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