Hardball Depo Tactics
Per Ervin Gonzalez, very accomplished litigator, you will often encounter opposing counsel who do everything possible to prevent you from conducting your deposition in an orderly fashion. Be aware of FRCP 1.310 which provides, in part, that “any objection during a deposition must be stated concisely and in a nonargumentative . . . manner.” The rule promotes civility. More on this in future Tips.