The decision for deposing a nonparty presents a Rubik’s cube of factors that need to be considered holistically to best prepare for trial. Trial preparation in civil litigation invariably involves the ...

Review the FRCP to understand the scope of permissible inquiry at a deposition. Under the FRCP, a deposing attorney may ask questions about any nonprivileged matter that is relevant to any party’s ...

Although the 4th U.S. Circuit Court of Appeals has not directly addressed whether the heightened pleading standards of Ashcroft v. Iqbal, 556 U.S. 662 (2009), and Bell Atlantic Corp. v. Twombly, 550 U ...

September 19, 2025 - Everyone knows the baseline rule: an attorney cannot, and should not, coach a witness on the record during a deposition or influence the witness to change testimony. A deposition ...

While parties should typically be permitted to attend depositions, there are practical, commonsense situations in which their physical presence should be limited or, more rarely, barred altogether. It ...