DEPOSITIONS
Make sure your opponent has complied with Rule 26 mandatory disclosure II. TAKING A DEP OSITION A. PRE-DEPOSITION PLANNING! Re-read Trial Rules 26, 28, 29, 30, and 37, and any applicabl e Local Rule.! Estimate how long you think deposition will take -- then double it ! Draft a Notice of Deposition (and subpoena if a non-party - - Rule 45).
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