How Soon Can You Seek a Deposition?

Before you serve a deposition notice, make sure your timing complies with the statutes. Continue reading

5 Steps to Responding to a Deposition Notice

After receiving a deposition notice or subpoena, counsel should to take a careful look at the documents served and make decisions about how to proceed. To organize the process, follow these five steps. Continue reading

What To Do When Person Most Knowledgeable Doesn’t Work There Anymore

ThinkstockPhotos-460156617If you represent an organization that gets served with a deposition notice under CCP §2025.230, you’ll need to designate “persons most knowledgeable” (PMK) to show up. This can be complicated, particularly if such employees are no longer with the organization or if the organization serves so many customers that getting called into depo in every case would be onerous. Never fear: the first problem can be dealt with by preparing current employees to speak to the issue, and the second may be eliminated by the courts. Continue reading