Free Order - District Court of Connecticut - Connecticut

w`“"* i
' l · I Case 3:08-cv-00930-CFD Document 47-3 Filed O1/26/2004 Page1of1
issuance of instructions directing the witness not to i
answer: the inappropriate answering of questions i
intended for the deponent; and the improper invoking of V
the attorney—client privilege and the work product ,
doctrine, sometimes blocking the answering of even i
foundation questions. - E
1. Outbursts and Non—Meritorious é
Objections Unrelated to Privilege
- Rule 30(c), Fed.R.Civ.P., provides in pertinent l
part that during oral examination "[ejvidence objected
to shall be taken subject to objections.“ This means
that "ordinarily the deponent shall answer all questions ;
U . . . , and that all . . . objections [other than those
based on privilege] shall be stated, but reserved until
the actual trial." 4A J. Moore, Federal Practice {30.59
at 145 (1990). The rule "means what it says." Ralston g
Purina Co. v. McFarland, 550 F.2d 967, 973 (4th Cir. Q
1977), citing Wright & Miller, Federal Practice and i
Procedure, Civil §21l3 at 419 n.22 (1970). i
Were the rule otherwise, "oral examinations would
be quickly reduced to an -exasperating cycle of
answerless inquiries and court orders." Shapiro v.
Freeman, 38 F.R.D. 308, 311 (S.D.N.Y. 1965).
Depositions would cease being the valuable discovery
tool envisioned by the Federal Rules of Civil Procedure.
Accordingly, objections unrelated to a claim of i
P i
3
1
l

—————————A———————————————————————————————————————————————————————·—r"trrtt“m""*7-