CONDUCT OF DEPOSITIONS

(a) Questions About an Asserted Privilege Counsel may question a deponent who refuses to answer a question on the basis of privilege about information related to the appropriateness of the privilege, including whether: (1) the privilege applies under the circumstances; (2) the privilege has been waived; or (3) circumstances exist to overcome a claim of qualified privilege. 59 | P a g e (b) Private Conference Regarding a Pending Question Counsel for a deponent may not initiate a private conference with the deponent during the deposition about a pending question except to determine whether to assert a claim of privilege. (c) Raising Objections with the Court A party may recess a deposition to submit an objection by phone to a Judge if the objection: (1) could cause the deposition to be terminated; and (2) can be resolved without submitting written materials to the Court. (d) Scheduling Depositions Counsel shall make a good faith effort to schedule depositions in a manner that avoids scheduling conflicts.

No deposition will be scheduled on less than 14 days’ notice unless agreed by counsel or the Court orders otherwise.