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Compelling a Pro Se Plaintiff’s Deposition

The Defendants attempted compelling unanswered discovery and a deposition of a Pro Se Plaintiff.  Adding to the Plaintiff’s problems, the Plaintiff failed to attend the motion to compel hearing.  Hart...

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It’s Not Paradise: Never Get the Judge to Call Your Conduct “Appalling”

The Defendants challenged a Magistrate Judge’s order that required two deponents to be re-deposed for two hours each, plus an additional $3,800 in reasonable expenses.  Funk v. Town of Paradise, 2011...

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30(b)(6) Depositions Doesn’t Not Mean Expert Opinions

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...

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When Asking for Expert Income is Overkill

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...

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