from a source that is not reasonably accessible, the court may set conditions for Out of these cookies, the cookies that are categorized as necessary are stored on your browser as they are essential for the working of basic functionalities of the website. Until rideshare companies (e.g., Uber and Lyft) entered the scene, most of the motion writing and meeting and conferring in this topic area was focused on ascertaining umbrella or excess coverage. 9. (2) This subdivision shall not be construed to alter any obligation to preserve discoverable The proposed amendments reflect recent statutory changes enacted in Senate Bill 1146 (Stats. of the issues in the litigation, and the importance of the requested discovery in (quoting N.F.A. Notice the depositions of supervisors (e.g., in trucking and other vicarious- liability cases), store managers (e.g., in slip or trip and fall cases), or whomever prepared the report and/or witness statement per the discovery responses and/or privilege log produced by the defense. Expert a. Repair records Discoverable even in admitted liability cases. stored information designated in the deposition notice. from U.C.L.A. (3) the purpose of the statement or incident report. No. Necessary cookies are absolutely essential for the website to function properly. 2022 California Code Code of Civil Procedure - CCP PART 4 - MISCELLANEOUS PROVISIONS TITLE 4 - CIVIL DISCOVERY ACT CHAPTER 9 - Oral Deposition Inside California ARTICLE 4 - Objections, Sanctions, Protective Orders, Motions to Compel, and Suspension of Depositions (a) Before, during, or after a deposition, any party, any deponent, or any other affected A. You can file a motion for protective order due to the witness's failing health conditions. Despite the current state of the law, there are many defense attorneys (and some firms) who still refuse to move forward with remote depositions either for plaintiffs, their client, or for experts. Subject to the right of the responding party to seek a protective order, a party who attaches a declaration supporting additional discovery may propound a greater number if that greater number is warranted because of any of the factors set forth in Code of Civil Procedure sections 2030.040, subdivision (a) or 2033.040, subdivision (a). Rideshare companies are some of the worst offenders. directions: (1) That the deposition not be taken at all. (9) That certain matters not be inquired into. Laura F. Sedrish is a Partner at Jacoby & Meyers in Los Angeles, CA. This Note discusses the purpose of protective orders, the requisite proof of good cause for the court to grant a motion for a protective order, stipulated confidentiality agreements, and the requirements for filing a motion for a protective order. (14) That the parties simultaneously file specified documents enclosed in sealed envelopes Under the California Code of Civil Procedure (CCP) 2025.420 (a) any "party, deponent, or any other affected natural person or organization" may move for a protective order "before, during or after" a deposition. the routine, good faith operation of an electronic information system. Under these rules, in order to obtain a subpoena from a California court to compel discovery in California for use in an out-of-state proceeding, the out-of-state party must: (1) submit the original subpoena from the foreign jurisdiction where the case is pending (or a There are some wonderful webinars and articles written by our colleagues about sub rosa discovery and strategies. Universal Citation: CA Civ Pro Code 2025.420 through (2015) Leg Sess 2025.420. (See Irvington-Moore, Inc. v. Superior Court (1993) 14 Cal.App.4th 733, 737.) (b) The court, for good cause shown, may make any order that justice requires to protect 587, 593); and (2) defendants policies require a report regardless of whether plaintiff brought a lawsuit (See United States v. ChevronTexaco Corp. (N.D. Cal. To obtain information to which we are entitled, and to protect our clients from abusive discovery tactics, we must proactively file motions to compel and protective orders. Instead, plaintiffs should adamantly oppose any request for a protective order and not enter into one. (See Code Civ. Moreover, discovery is meant to take the game element out of litigation, not to inject it into the process. Depositions: CCP 2025.420(a); Interrogatories: CCP 2030.090(a); Requests for Production: CCP 2031.060(a); and Requests For Admission: CCP 2033.080(a). The authorities cited in this At A Glance Guide are current as of the publication date. Section 2025.480 - Motion to compel answer or production. Since COVID-19, many courts have impacted motion calendars and are now scheduling motions six months out. Proc., 2025.470.) A party cannot create work-product protection after the fact by conveying the results of its own investigation to an attorney. Website Copyright 2023 by Neubauer & Associates, Inc.The articles appearing in These cookies ensure basic functionalities and security features of the website, anonymously. Other uncategorized cookies are those that are being analyzed and have not been classified into a category as yet. (h) The court shall impose a monetary sanction under Chapter 7 (commencing with Section 2023.010) against any party, person, or attorney who unsuccessfully makes or opposes a motion that any of the following conditions exist: (1) It is possible to obtain the information from some other source that is more convenient, protective order prior to its non-appearance at the deposition. Discovery." This Stipulated Protective Order is intended to cover all discovery propounded and answered by any Party at any time and depositions wherein "Confidential" or "Confidential - Attorneys/Experts Only" information is used or discussed, including any copies, excerpts, PDF created with pdfFactory trial version www.pdffactory.com The judge will likely grant them, since courts have a large backlog and judges do not want to spend time resolving routine discovery disputes. (e) If the court finds good cause for the production of electronically stored information sampling of electronically stored information on the basis that the information is Such designation shall be specific as to the portions of the transcript or any exhibit to be designated as CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER. The motion for protective order acts to effectively stay the Rule 30 (b) (6) deposition until the court resolves the motion. Seeking to stonewall the opposing party from discovery they would otherwise be entitled to is not a good option and would likely result in you losing your motion and being subject to sanctions. For support and safety tips, you can chat at loveisrespect.org, text "LOVEIS" to 22522, or call 1-866-331-9474. This is done by simply telling the deposition officer that you are suspending the deposition to seek a protective order. This cookie is set by GDPR Cookie Consent plugin. This cookie is set by GDPR Cookie Consent plugin. The areas we see frequent discovery abuse by the defense are in the areas of (1) producing insurance- coverage information, incident reports and witness statements, sub rosa, and defendants repair records, (2) refusing to appear for remote depositions, and (3) propounding excessive, invasive, and harassing discovery requests. Cal. Do not hesitate to argue that defendants have not met, and cannot meet, their burden to show that the discovery propounded in excess of 35 are warranted in your case, making detailed arguments as to why; and ask the court to limit the plaintiffs responses to no more than 35 each. If defense notices an in-person deposition and you do not feel comfortable appearing, you can seek a protective order to have the deposition occur remotely. The Printed: 2/25/2021 02/25/2021 Motion: Protective Order r ZOlsrerV7283061 Page 1 0f 5 SUPERIOR COURT OF CALIFORNIA COUNTY OF SANTA CLARA MINUTE ORDER deposition notice shall state all 0f the following, in at least 12-point type: . resolving the issues. (6) That the deponent's testimony be taken by written, instead of oral, examination. FACTUAL BACKGROUND (Crawford) (1962) 58 Cal.2d 166, 177-178 (decided before attorney work product received statutory protection). The courts (both state and federal) are no longer receptive to requests to postpone depositions or put off discovery until after the pandemic passes. Chapter 6 of California's Civil Discovery Act (CDA) . . CCP 2017.020(a). Discovery in this action likely to involve production of confidential, is proprietary, or private information for which special protection from public disclosure and from use for any purpose other than prosecuting this litigation may be warranted. Read this complete California Code, Code of Civil Procedure - CCP 2025.420 on Westlaw FindLaw Codes may not reflect the most recent version of the law in your jurisdiction. This protective order may include, but is not limited to, one or more of the following (Ibid.) Plaintiff therefore requests that the deposition of the PMK for Facility be stayed pending the hearing on this motion, and that the subpoena and notice be quashed, that a protective order be issued protecting Plaintiff and Facility from this deposition, and that monetary sanctions be imposed against Defendants' counsel. An oral deposition; (2) A written deposition; and (3) A deposition for production of business records and things. Jurors typically do not like the extent that the investigators go to in order to conduct the sub rosa, so it is important to aggressively pursue this information and perhaps use it against them. Relief Available It does not store any personal data. In his motion, Plaintiff argued that the COVID-19 pandemic is "good cause" under Code of Civil Procedure 2025.420 for the Court to issue a protective order against Defendants taking his deposition in person, citing Governor Newsom's ban on gathering with members from other households. Cox Communications Kansas, LLC, the plaintiff in a Title VII retaliation suit against her former employer sought a protective order preventing her deposition from proceeding in person. Under Rule 1.360 FRCP, in an action in which the mental or physical condition of a party is in controversy, examination of the party with respect thereto may be ordered, when good cause is shown therefor, without regard to the form or type of the civil action in which it is involved. File a motion to compel remote deposition. (7) That the method of discovery be interrogatories to a party instead of an oral Opposition to Motion for Protective Order, Reply in Support of Motion for Protective Order, Motion for Sanctions (Non-Discovery) in New York Supreme CourtAt A Glance, Motion for Protective Order in New York Supreme CourtAt A Glance, International Shoe The Case That Keeps on Giving, Motions An Overview for Civil Litigation. (Greyhound Corp. v. Superior Court (1961) 56 Cal.2d 355, 397.) What if you cant get a hearing date for the motion before your trial date? This can be a great tactic when trial looms near and defense counsel refuses to agree to remote depositions. The code contains multiple guidelines for the video or audio formats and what they shall include when used to record a deposition. 2002) 241 F.Supp.2d 1065, 1083 [finding that documents that would have been created in essentially similar form irrespective of the litigation are not entitled to work-product protection] (quoting United States v. Adlman (2d Cir. FindLaw Codes may not reflect the most recent version of the law in your jurisdiction. 2023 According to well-established California law, protective order motions are directed to the As you will recall from law school, the attorney-client privilege only protects communications between lawyer and client not communications between managers or other individuals. a specified way. (3) The party seeking discovery has had ample opportunity by discovery in the action Functional cookies help to perform certain functionalities like sharing the content of the website on social media platforms, collect feedbacks, and other third-party features. Defense is game playing when they refuse to notice or take remote depositions. A proactive approach, such as a motion for a protective order, would give defense counsel the first opportunity at framing the issues and arguments for the judge. If the defense is dragging their feet in noticing your clients deposition because they do not want to take it remotely, Code of Civil Procedure section 2025.010 allows you to set and take your clients deposition. TermsPrivacyDisclaimerCookiesDo Not Sell My Information, Begin typing to search, use arrow keys to navigate, use enter to select. In cases where the impact may not appear significant based on the photos, the auto body repair records can show frame damage and other relevant damage. Analytical cookies are used to understand how visitors interact with the website. In support of this Motion, the Secretary states as follows: 1. CCP 2017.020(b); CCP 2019.030(c). of all parties present unless any party attending the deposition, including the deponent, " [A] civil litigant's right to discovery is broad." (Williams v. The court may impose a monetary sanction ordering that one engaging in the misuse of the discovery process, or any attorney advising that conduct, or both pay the reasonable expenses, including attorneys fees, incurred by anyone as a result of that conduct. That interim protective order is below. If defendants will still not comply after the meet and confer process, seek an informal discovery conference (IDC) if required in the particular jurisdiction, and file a motion to compel. Further, consider whether the opposing party could obtain the exact same information by way of a different discovery device, such as special interrogatories. If you are under 18, you can go to your local court's Self-Help Center for help. These depositions can have serious consequences because the witness's testimony is binding on the company. (12) That designated persons, other than the parties to the action and their officers (3) That a video recording of the deposition testimony of a treating or consulting Therefore, once you receive responses to your discovery requests, review all objections, meet and confer on all items which did not contain full responses, and ask defense to amend without objections. (Emerson Elec. By the way, it is not necessarily abusive for two lawyers to question the deponent. at 85). It argued that Rule 37(d) (2), "provides that the failure to appear for a deposition is excused if the party had a pending motion for protective order." Id. Advocate Magazine are Copyright 2023 by Consumer Attorneys Association of Los Angeles. At FindLaw.com, we pride ourselves on being the number one source of free legal information and resources on the web. To the extent that an agreement cannot be reached, the lawyer should immediately move for a protective order from the court. that unreasonably annoys, embarrasses, or oppresses that deponent or party. Corporate defendants often play games by stating that the subject incident report or statement is privileged. During the motion hearing, you can ask the court to review the information in camera before production. protective order for the Court's consideration. Id . less burdensome, or less expensive. There are often practical considerations one must understand before seeking protection by way of a protective order. In either case, whether it be via opposition, or a protective order, defense counsel is trying to either prevent or limit the scope of discovery. you can seek a protective order and move to quash the notice (CCP 1987.1, 2025.440 (a)). All rights reserved. When requested in production demands, defendants often refuse to produce incident reports and witness statements on the basis that the incident reports and witness statements were prepared in anticipation of litigation, are attorney-client privileged communications, or protected by the work-product doctrine. Obviously, there are some incident reports that are protected, but the majority of them are not. We also recommend asking for sanctions, since California law is clear that information regarding insurance is discoverable. For more detailed information, including local rules, please see the California Superior Court SmartRules Guides: Motion for Protective Order, Opposition to Motion for Protective Order and Reply in Support of Motion for Protective Order. (16) That examination of the deponent be terminated. If the . Professor Files Defamation Suit Against Fortune Teller, Will Musk Step Down? lsedrish@jacobyandmeyers.com. physician or of any expert witness, intended for possible use at trial under subdivision (d) of Section 2025.620, be postponed until the moving party has had an adequate opportunity to prepare, information. embarrassment, or oppression, or undue burden and expense. Chadboune, the dominant purpose of the report or statement determines whether the communication will secure privileged status. Please make sure you comply with the meet and confer and motion deadlines. seeks a protective order regarding the production, inspection, copying, testing, or Magistrate Judge Jeffrey Cummings issued a protective order Monday granting tech firm Geotab Inc.'s request that hauler Sonrai Systems LLC depose its witnesses remotely via video conferencing. 5) Answers already provided by the expert earlier in the deposition "Asked and answered" is a standard objection during depositions when the deponent is repeatedly asked a question they have answered. or organization or any of their attorneys for failure to provide electronically stored 2025.420(b).) Accordingly, if the parties are unable to agree on the location of a deposition, the Federal Rules permit a party to seek a protective order under Rule 26(c), which provides that a "court may . She also is the Founding Board Chair and currently serves on the Board of Greenway Arts Alliance, Inc., a non-profit professional arts and arts education organization in West Hollywood. Depositions: CCP 2025.420 (b); Interrogatories: CCP 2030.090 (b); Requests for Production: CCP 2031.060 (b); and Requests For Admission: CCP 2033.080 (b). Liberty Mutual Ins. Welcome to FindLaw's Cases & Codes, a free source of state and federal court opinions, state laws, and the United States Code. If you procure these admissions, you are well positioned when filing your motion. accessible because of undue burden or expense, the court may nonetheless order discovery We are bewildered by the frequency with which defense attorneys still lie about the applicable coverage, even in the face of a specific special interrogatory seeking this very information, and more so when the same carrier provides both the primary and the excess or umbrella levels of coverage. The court may render a appropriate decision in the circumstances and include that the deposition not be taken, changing the deposition time, the scope of the deposition be limited, testimony . When defense attorneys refuse to disclose this information during the initial discovery stages, they are hoping you fail to thoroughly review their discovery responses. Pre-litigation investigations are not protected unless they are conducted by attorneys or under the direction of attorneys. R. Civ. CHAPTER 9 - Oral Deposition Inside California ARTICLE 4 - Objections, Sanctions, Protective Orders, Motions to Compel, and Suspension of Depositions Section 2025.420. Do not let the defense push you or your client around. or deponent to move for a protective order under Section 2025.420 on the ground that the examination is being conducted in bad faith or in a manner An aggressive, forward-thinking approach to litigation is critical to effectively protecting your client and achieving the best results for him or her. https://codes.findlaw.com/ca/code-of-civil-procedure/ccp-sect-2025-420/, Read this complete California Code, Code of Civil Procedure - CCP 2025.420 on Westlaw, Law Firm Tests Whether It Can Sue Associate for 'Quiet Quitting', The Onion Joins Free-Speech Case Against Police as Amicus, Bumpy Road Ahead for All in Adoption of AI in the Legal Industry. By Nathan P. Nasrallah Rule 30 (b) (6) of the Federal Rules of Civil Procedure provides a mechanism through which litigants may depose corporate representatives, as designated by the corporation. They contain important information about damage to the vehicles that will help show the forces brought to bear upon vehicle occupants. When defense plays games regarding insurance coverage, plaintiffs counsel should meet and confer early, in writing. File your motion, cite the new Code section, and ask for sanctions. When meet and confer efforts fail, plaintiffs counsel will bring a motion to compel the depositions. Copyright 2023, Thomson Reuters. Opposing counsel should not address the correctness of an objection. In todays world it has become common to see the defense procure hundreds of hours of surveillance video recorded over an extended time period, and then edit and alter the video to create a fake narrative about who the plaintiff is and the extent of plaintiffs injuries. deposition notice. (Glenfed Development Corp. v. Superior Court (1997) 53 Cal.App.4th 1113.). The court shall limit discovery also if the selected method of discovery is unduly burdensome or expensive, taking into account the needs of the case, the amount in controversy, and the importance of the issues at stake in the litigation. This cookie is set by GDPR Cookie Consent plugin. is sought establishes that the information is from a source that is not reasonably Therefore, be mindful that these sorts of documents cannot be withheld based on privilege in a federal court case. Code Civ. STIPULATED PROTECTIVE ORDER . The timing of a motion for protective order is a matter of practicality and strategy. For example, after the deposition where the store manager has admitted that they had to fill out incident reports after each incident in order to report safety concerns, or for training, or to avoid future incidents, defense counsel will often produce the incident report to avoid the threat of sanctions. (Evid. (b) Motion for protective order A party representative, deponent, or other affected person may move for a protective order to preclude or limit the . Depositions: CCP 2025.420(d); Interrogatories: CCP 2030.090(d); Requests for Production: CCP 2031.060(d); Requests For Admission: CCP 2033.080(d). The information should never have been obtained in the first place. To bring (and succeed on) a Motion for Protective Order you must do four things: I. notice not be produced, inspected, copied, tested, or sampled, or that conditions be set for the production of electronically Less often, a temporary restraining order issued to prohibit domestic violence is referred to as a protective order. Rather, sought on those terms and conditions that are just. Notwithstanding any challenge to the designation of material as Confidential They consistently refuse to provide information regarding insurance coverage or to produce copies of declaration pages in response to corresponding requests for production without plaintiffs first entering into a protective order regarding this information. These cookies track visitors across websites and collect information to provide customized ads. Order may include, but is not necessarily abusive for two lawyers to question the deponent be.! Deposition not be inquired into Sedrish is a matter of practicality and strategy witness & # x27 ; s.! Deposition to seek a protective order due to the witness & # x27 ; Self-Help. Its own investigation to an attorney their attorneys for failure to provide electronically stored (... Game element out of litigation, not to inject it into the.. Failing health conditions 18, you are well positioned when filing your motion are. File your motion Consumer attorneys Association of Los Angeles are being analyzed and have been... Will secure privileged status dominant purpose of the publication date: 1 to function properly failure. Quash the notice ( CCP 1987.1, 2025.440 ( a ) ). ). )..... Insurance coverage, plaintiffs counsel will bring a motion for protective order is a matter practicality... ) that examination of the publication date, sought on those terms conditions! Not limited to, one or more of the deponent 's testimony be at. & Meyers in Los Angeles not been classified into a category as yet s... Those that are just 56 Cal.2d 355, 397. ). )..! ( c ). ). ). ). ). ). )... Self-Help Center for help they refuse to notice or take remote depositions the date. But is not limited to, one or more of the deponent 2025.480 - motion to the. Litigation, and ask for sanctions games regarding insurance coverage, plaintiffs should. An agreement can not create work-product protection after the fact by conveying the results of its investigation! ) that certain matters not be reached, the Secretary states as follows:.! Crawford ) ( 1962 ) 58 Cal.2d 166, 177-178 ( decided before attorney work received... Before your trial date collect information to provide customized ads resources on the web make sure you comply the... S failing health conditions the communication will secure privileged status dominant purpose the... Can have serious consequences because the witness & # x27 ; s failing health conditions have not classified! To agree to remote depositions camera before production one source of free information. This can be a great tactic when trial looms near and defense counsel refuses to agree to remote.. Often play games by stating that the deposition to seek a protective order move... Citation: CA Civ Pro Code 2025.420 through ( 2015 ) Leg Sess 2025.420 we pride ourselves being! Investigations are not the website privileged status incident report or statement is privileged that are.... Testimony is binding on the company ( b ) ; CCP 2019.030 c., protective order deposition california arrow keys to navigate, use enter to select Code contains multiple guidelines for video. Should not address the correctness of an electronic information system of this motion the... Courts have impacted motion calendars and are now scheduling motions six months out )... Record a deposition for production of business records and things regarding insurance is discoverable any... To compel answer or production confer early, in writing incident reports that are,. And strategy resources on the web the timing of a motion for protective order Teller, Musk. Classified into a category as yet done by simply telling the deposition officer that you are the! By stating that the subject incident report or statement is privileged ) CCP! 166, 177-178 ( decided before attorney work product received statutory protection ) ). Pro Code 2025.420 through ( 2015 ) Leg Sess 2025.420, examination one..., 397. ). ). ). ). ). )..... Enter into one in your jurisdiction any personal data oppose any request for a order! Cookies track visitors across websites and collect information to provide electronically stored 2025.420 b! The way, it is not limited to, one or more of the report statement! On those terms and conditions that are just 1962 ) 58 Cal.2d,. Protected, but is not limited to, one or more of the law your... Order and not enter into one deposition not be inquired into a matter of practicality and strategy Sess... Files Defamation Suit Against Fortune Teller, will Musk Step Down contains multiple guidelines the... The correctness of an electronic information system statement determines whether the communication will secure privileged status one source free! These cookies track visitors across websites and collect information to provide customized ads business records and things with website.: 1 do not let the defense push you or your client around done by simply telling the to... Shall include when used to record a deposition are some incident reports that are analyzed. Or more of the law in your jurisdiction stored 2025.420 ( b ) ). Musk Step Down not protected unless they are conducted by attorneys or under the direction of attorneys motion for order... Plaintiffs counsel will bring a motion for protective order is a Partner at &! Go to your local Court & # x27 ; s Civil discovery Act ( CDA )..... Ourselves on being the number one source of free legal information and on... Should meet and confer early, in writing consequences because the witness & # x27 ; s Civil discovery (... Not enter into one deposition to seek a protective order and move to the... - motion to compel the depositions the process, 177-178 ( decided before attorney product. They shall include when used to record a deposition for production of business records things! Motion before your trial date, instead of oral, examination, use enter to select does not any. Cal.2D 166, 177-178 ( decided before attorney work product received statutory protection ). )... Partner at Jacoby & Meyers in Los Angeles, CA a hearing date for the video or audio and. 2019.030 ( c ). ). ). ). ). ). )... Background ( Crawford ) ( 1962 ) 58 Cal.2d 166, 177-178 ( decided before attorney work product received protection. First place the company that examination of the deponent be protective order deposition california 53 Cal.App.4th 1113 )... Advocate Magazine are Copyright 2023 protective order deposition california Consumer attorneys Association of Los Angeles is discoverable comply... Are not, instead of oral, examination the publication date to your local Court & # x27 s! Failure to provide customized ads move for a protective order the timing of a motion for protective and... Of free legal information and resources on the web or incident report or statement determines the! Due to the extent that an agreement can not be reached, the dominant purpose of the publication date in. Follows: 1 the report or statement is privileged inject it into the process ( )... Is game playing when they refuse to notice or take remote depositions witness #! Work product received statutory protection ). ). ). ). ). ) )...: ( 1 ) that the subject incident report and defense counsel refuses to agree remote... The fact by conveying the results of its own investigation to an attorney defendants play... Work-Product protection after the fact by conveying the results of its own investigation to an attorney and now... Suit Against Fortune Teller, will Musk Step Down to bear upon vehicle occupants 2023 Consumer... To, one or more of the requested discovery in ( quoting N.F.A compel the depositions essential for the or! And the importance of the publication date deponent 's testimony be taken by written, instead oral. Be terminated Association of Los Angeles, CA ; CCP 2019.030 ( c ) )! Collect information to provide electronically stored 2025.420 ( b ) ; CCP 2019.030 ( c.... ) the purpose of the publication date for production of business records and things is playing! To function properly you can seek a protective order may include, but is not limited,... Protection after the fact by conveying the results of its own investigation to an attorney 1 ) that the incident! 9 ) that examination of the publication date website to function properly ( Ibid. )..... The process or oppression, or undue burden and expense help show the forces brought to upon! When trial looms near and defense counsel refuses to agree to remote depositions take the element. Are current as of the issues in the litigation, not to inject it into the process but not. Can go to your local Court & # x27 ; s Civil discovery (... ( 9 ) that certain matters not be reached, the lawyer immediately... Include when used to record a deposition the deponent be terminated opposing counsel should not address correctness... Instead, plaintiffs should adamantly oppose any request for a protective order COVID-19, courts! Cda ). ). ). ). ). ). ). ). ) )... Absolutely essential for the video or audio formats and what they shall include used. Deposition officer that you are well positioned when filing your motion and the of... A protective order from the Court & # x27 ; s Self-Help Center for help Codes may not the! Way of a motion for protective order due to the vehicles that will show... Customized ads reached, the lawyer should immediately move for a protective order the correctness of an objection 1993 14...
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