Without a Doubt Blog


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August 25th 2011 10:44AM
The Defendants’ Expert Witness was deposed on his annual earnings from providing expert testimony.  The expert claimed that information was private information and he refused to answer.  A motion to compel followed.  Young v. Pleasant Valley Sch. Dist., 2...
August 16th 2011 8:26AM
The Plaintiff, a Pro Se parolee, brought a motion for the Defendants to pay for his own deposition against the State of California, to be held in Sacramento.  Strong v. Elliott, 2011 U.S. Dist. LEXIS 89106, 2-3 (E.D. Cal. Aug. 11, 2011). The Plaintiff cla...
August 10th 2011 9:01AM
The Plaintiff sought the Defendants to produce advanced copies of their potential non-Bates numbered deposition exhibits 72 hours before the deposition.  The Defendants naturally said “No,” claiming the Plaintiffs were seeking information protected by the...
August 3rd 2011 9:04AM
The Plaintiffs brought a motion to compel and sanctions pursuant to Federal Rules of Civil Procedure Rules 30(d)(2) and 37(a), claiming the Defendant’s 30(b)(6) witness was “unprepared or unwilling” to answer deposition questions.  Hund v. Smith & Nep...
July 13th 2011 9:23AM
A Defense Deponent testified she knew a broker who gave an improper kickback to another broker.  When asked to identify the person involved in the kickback, the Deponent answered, “I don’t want to use the name. I can’t do that.” LM...