Deposition Law and Strategy (One Volume)
Steven E. North, Francis A. C. Sevier
Price: $175.00 900 pages. 1 Looseleaf Volume. Index. Updated annually or when needed. One 3.5" Diskette.
ISBN-13: 978-1-57823-101-0 / ISBN-10: 1-57823-101-9
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PART I INTRODUCTION TO DEPOSITION STRATEGY
Intro.01 Scope of Chapter
Intro.02 Pre-Deposition Considerations
[1]—Objectives of the Deposition; Why Take the Deposition
[a]—Generally
[b]—As a Discovery Device
[c]—To Perpetuate Testimony
[d]—To Pin Down a Story
[e]—To Authenticate Documents
[f]—To Obtain Admissions
[g]—As a Strategy Tool
[2]—Initial Planning
[a]—Generally
[b]—Whether to Take Depositions
[i]—Advantages of Noticing Depositions
[ii]—Disadvantages of Noticing Depositions
[iii]—Alternatives to Noticing Depositions
[c]—Drafting Pleadings to Facilitate Discovery
[d]—Where to Take Depositions
[e]—Who Should Be Examined
[i]—Generally
[ii]—Depositions of Parties
[iii]—Depositions of Nonparties and Corporate Representatives
[iv]—Out-Of-State Witnesses
[f]—Determination of Witness Order
[g]—Timing of Deposition
[h]—Videotaping Deposition
[i]—Generally
[ii]—Advantages
[iii]—Disadvantages
[3]—Preparation for the Deposition by the Examining Attorney
[a]—Generally
[b]—Examination of Documents and Materials
[c]—Interviews
[d]—Who Is the Witness
[e]—Written Preparatory Material
[i]—List of Verbatim Questions
[ii]—Outline of Subjects of Questions
[iii]—List of Facts
[iv]—Preparation of Questions About Documents
[f]—Organization of Preparatory Material
[g]—Choosing a Reporter
[4]—Preparation of Witness' Attorneys
[a]—Analysis of Issues
[b]—Review and Preparation of Documents
[c]—Final Preparation
[5]—Preparation of a Party Witness
[a]—Initial Contact
[b]—Stages of Witness Preparation
[i]—”Warm-up” Process
[ii]—Account of Events Known to Witness
[iii]—Questioning and Resolving Inconsistencies
[iv]—Document Review
[v]—Instructions to Witness
[A]—Generally
[B]—Nature and Scope of Testimony
[C]—Manner of Giving Testimony
[D]—Relationship With Others
[E]—Physical Matters
[vi]—Final Touches
[c]—Dealing With Special Problems
[d]—Attorney-Client Privilege
[6]—Preparation of Nonparty Witness
[a]—Generally
[b]—Witness' Counsel
[c]—Preparation of an Expert
[d]—Cautionary Note
[7]—Production of Documents at the Deposition—Subpoena Duces Tecum
Intro.03 Conduct of the Deposition
[1]—Initial Considerations
[a]—Location of the Deposition
[i]—Office of Deposing Counsel
[ii]—Depositions in the Courthouse
[b]—Who Should Be Present
[i]—Other Counsel
[ii]—Client and Non-Lawyers
[c]—Stipulations
[d]—Understandings With Deponent's Attorneys
[e]—Determination of Witness Order
[2]—Commencing the Deposition
[3]—Scope of Deposition
[4]—Conducting the Deposition
[a]—Control
[b]—Organization
[c]—Questioning Techniques
[d]—Paying Attention to the Witness' Answers
[e]—Counteracting Objections
[f]—Instructions Not to Answer
[g]—Probing Complete Recollection
[h]—Conferences With Counsel
[5]—Expert Witnesses
[a]—Generally
[b]—Cooperative Witness
[c]—Hostile Witness
[d]—Outline of Areas to be Covered
[6]—Nonparty Witnesses
[a]—Hostile Nonparty Witnesses
[b]—Friendly Nonparty Witnesses
[c]—Neutral Nonparty Witnesses
[d]—Objections
[7]—Examination of Documents and Other Material
[8]—Terminating the Examination
[a]—When to Stop Questioning
[b]—Seeking Court Intervention—Summary Rulings
[i]—Generally
[ii]—Making a Good Record
[iii]—Requesting Rulings to Help the Witness
[iv]—Rulings by a Law Secretary
[v]—Reluctance of Examining Counsel to Go for Rulings
[vi]—When to Seek or Consent to a Ruling
[vii]—List of Objections
[9]—Illustrative Deposition
Intro.04 Defending at the Deposition
[1]—Role of Counsel for the Party Witness
[a]—Defining Your Objectives
[b]—Determining Scope of Examination
[c]—Dealing With Non-Responsive Answers
[d]—Notetaking
[e]—Overseeing Client
[2]—Role of the Counsel for the Third Party Witness
[a]—Objecting
[b]—Interrelating the Testimony and Positions
[c]—Avoiding Interference
[3]—Role of Counsel for the Expert Witness
[4]—Objections
[a]—Generally
[i]—Law
[ii]—Approach and Strategy
[iii]—Abusive Adversary
[b]—Form of Objection
[c]—Objections as to Form
[i]—Already Asked and Answered
[ii]—Without Proper Foundation
[iii]—Compound Question
[iv]—Ambiguous
[v]—Excessively Broad
[vi]—Argumentative
[vii]—Nonsensical
[viii]—Misleading
[ix]—Leading Question
[d]—Objections as to Substance
[i]—Objections Based Upon Privilege
[ii]—Objections Based Upon Competency of Witness
[iii]—Opinion Testimony
[iv]—Speculation
[v]—Hearsay
[vi]—Relevancy
[vii]—Harassment
[viii]—Objections Which May Cure Errors in the Questions
[e]—Objections to Answers
[i]—Timing of Objections
[ii]—Objection to Form of Answer
[f]—Waiver of Objections
[g]—Checklist of Objections
[i]— Objections as to Form
[ii]— Objections as to Substance
Intro.05 Post-Deposition Considerations
[1]—Statement on the Record
[2]—Signing of the Transcript
[3]—Transcripts
[a]—Generally
[b]—Correcting Inaccuracies
[c]—Filing Transcript
[4]—Indexing of Depositions
[5]—Use of Computers
[6]—Use of Deposition Transcripts
[a]—Motion Practice
[b]—Use at Trial
[c]—Impeachment
[d]—Evidentiary Problems
Intro.06 Illustrative Forms of Deposition Strategy
[1]—Introduction
FORM NO. Intro-1: Deposition of Defendant Radiologist by Counsel for Plaintiff/Decedent
FORM NO. Intro-2: Deposition of Party Defendant/Radiologist Taken by Counsel for Plaintiff/Decedent
FORM NO. Intro-3: Deposition of Attending Anesthesiologist Taken by Counsel for Plaintiff/Decedent
PART II DEPOSITION LAW
Dep.Law.01 Depositions Upon Oral Examination
[1]—General Principles Governing the Taking of Depositions
[a]—The 1993 Amendments
[b]—Rule 26—General Provisions Governing Discovery; Duty of Disclosure
[i]—Initial Disclosures
[ii]—Disclosure of Expert Testimony
[iii]—Other Pretrial Disclosures
[iv]—Discovery Scope and Limits
[v]—Protective Orders
[vi]—Timing and Sequence of Discovery
[vii]—Supplementation of Disclosures and Responses
[viii]—Planning Meeting of Parties; Discovery Plan
[ix]—Signing of disclosures, Discovery Requests, Responses and Objections
[c]—When Depositions May Be Taken Without Leave of Court
[d]—When Depositions Require Leave of Court
[i]—Deponent in Prison
[ii]—More Than 10 Depositions
[iii]—Persons Already Deposed
[iv]—Deposition Before Planning Meeting
[e]—Who May Be Deposed and Upon Which Matters the Deponent May Be Questioned
[i]—In General
[ii]—Expert Witnesses
[iii]—Incompetent Witnesses and First-Hand Knowledge Requirement
[iv]—Corporations
[f]—Failure to Make Disclosure or Cooperate in Discovery
[i]—Motion to Compel Discovery
[ii]—Failure to Comply With Order
[iii]—Self-Executing Sanctions
[g]—Compelling the Attendance of Witnesses at Deposition
[i]—Parties
[A]—Generally
[B]—Types of Sanctions
[ii]—Nonparties
[A]—Generally
[B]—Subpoenas Ad Testificandum
[C]—Production of Documents
[D]—Failure to Obey a Subpoena
[2]—Notice of Deposition—FRCP 30(b)
[a]—Form and Contents of Notice of Deposition—FRCP 30(b)(1)
[b]—Recording of Depositions
[i]—Generally
[ii]—Recording by Stenographer
[iii]—Nonstenographic Depositions
[c]—Requests for the Production of Documents at Deposition—FRCP 30(b)(5)
[d]—Requests for Designation of a Deponent—FRCP 30(b)(6)
[e]—Telephone Depositions—FRCP 30(b)(7)
[3]—Procedure for the Taking of Testimony at Deposition—FRCP 30(c)
[a]—Generally
[b]—Cross-Examination
[c]—Production of Documents Used to Refresh Recollection
[d]—Objections and Instructions During the Deposition
[4]—Protective Orders—FRCP 26(c) and 30(d)
[a]—Generally
[b]—Protective Orders Pursuant to FRCP 26(c)
[c]—Protective Orders Pursuant to FRCP 30(d)(3)
[5]—Submission of the Deposition to the Witness for Correction and Signature—FRCP 30(e)
[6]—Certification and Filing of Depositions—FRCP 30(f)
[7]—Sanctions for the Failure of the Party Giving Notice to Attend the Deposition or Serve a Subpoena—FRCP 30(g)
[8]—Taxation of the Costs of Depositions—FRCP 54(d)
[a]—Rule 54(d)
[b]—Assessment of Costs; In General
[c]—Assessment of Witness Costs
[d]—Assessment of Transcript and Copy Costs; the “Necessarily Obtained” Requirement
[e]—Assessment of Docket Fees
[f]—Imposition of Costs; Procedure
Dep.Law.02 Depositions Upon Written Questions—FRCP 31
[1]—Procedure for Taking
[a]—Service of Notice and Examination—FRCP 31(a)
[b]—Preparation of the Deposition Record—FRCP 31(b)
[c]—Notice of Filing of the Deposition—FRCP 31(c)
[2]—Factors Influencing the Determination to Proceed on Oral or Written Questions
[a]—Generally
[b]—Determination by Court Order
[c]—Costs
[d]—Place of Examination
[e]—Cross-Examination and Cross-Questions
Dep.Law.03 Use of Depositions in Court Proceedings—FRCP 32
[1]—Preliminary Requirements for Admissibility—FRCP 32(a)
[a]—Notice
[b]—Exceptions to Preliminary Requirements
[2]—Use of Deposition for Impeachment and as Substantive Evidence Under Rule 32(a)(1)
[a]—Impeachment
[b]—Substantive Evidence
[3]—Use of Adverse Party’s Deposition
[a]—Generally
[b]—Officer, Director, Managing Agent or Other Representative of Party
[4]—Use of Witness’ Deposition
[a]—Death of Witness
[b]—The Hundred Mile Provision
[c]—Location of the Witness
[d]—Time of Absence
[e]—Court’s Discretion
[f]—Absense Procured by Party
[g]—Absence Due to Age, Illness, Infirmity or Imprisonment
[h]—Inability to Procure the Attendance of the Witness by Subpoena
[i]—Exceptional Circumstances
[5]—Use of Party’s Own Deposition
[a]—Generally
[b]—The Hundred Mile Provision
[c]—Absence
[6]—Application of Federal Rules of Evidence
[a]—Hearsay
[b]—Relevancy and Competency
[c]—Broad Use Authorized
[d]—Prior Testimony of Unavailable Witness
[e]—Conformity of Procedure Rules
[7]—Objections
[a]—Generally
[b]—Privilege
[c]—Order To Compel Answers
[d]—Objections at Trial to Admissibility
[e]—Errors and Irregularities
[f]—Preclusion of Testimony
[g]—Objections as to Notice to Take Depositions
[h]—Disqualification of Officer
[i]—Objections as to Errors and Irregularities
[j]—Competency, Relevancy and Materiality
[k]—Objections as to Procedural Matters
[l]—Form of Questions and Answers
[m]—Application of Waiver Provision
[n]—Written Questions
[o]—Completion and Return of Depositions
Dep.Law.04 Perpetuation of Testimony by Deposition—FRCP 27
[1]—Introduction
[2]—Perpetuation of Testimony Before Action—FRCP 27(a)
[a]—Preliminary Showings Required Under FRCP 27(a)(1)
[i]—Jurisdiction
[ii]—Venue
[b]—Substantive Contents of Rule 27(a) Petitions
[i]—Generally
[ii]—Cognizability
[iii]—Inability to Presently Initiate the Anticipated Action
[iv]—The Subject Matter of, and Petitioner’s Interest in, the Anticipated Action
[v]—The Facts to Be Established and the Reasons for Desiring Perpetuation
[vi]—Names and Addresses of Expected Adverse Parties
[vii]—Names and Addresses of Deponents and the Substance of Their Expected Testimony
[c]—Formal Requisites of Petitions to Perpetuate Testimony
[d]—Contents of Notice and Requirements for Service Thereof—FRCP 27(a)(2)
[e]—Hearings on Petitions to Perpetuate and Orders Issued Pursuant to FRCP 27(a)(3)
[f]—Appealability of Rule 27 Orders
[g]—Use of Perpetuated Evidence—FRCP 27(a)(4)
[3]—Perpetuation of Testimony Pending Appeal—FRCP 27(b)
[4]—Actions to Perpetuate Testimony—FRCP 27(c)
Dep.Law.05 Persons Before Whom Depositions May Be Taken—FRCP 28
[1]—Within the United States—FRCP 28(a)
[2]—In Foreign Countries—FRCP 28(b)
[a]—Generally
[b]—Pursuant to Treaty
[c]—Notice Procedure
[d]—Commissions
[e]—Letters of Request (Letters Rogatory)
[i]—Purpose
[ii]—Procedure
[3]—Compelling the Appearance of Non-Resident Americans at Depositions—28 U.S.C. §§ 1783, 1784
[4]—Taking Depositions in the United States Under Foreign Letters of Request—28 U.S.C. § 1782
[5]—Disqualification for Interest—FRCP 28(c)
Dep.Law.06 Stipulations Regarding Discovery Procedure—FRCP 29
Dep.Law.07 Forms for Deposition Motion Practice (also on the diskette)
FORM NO. 1: Notice of Motion for Protective Order—FRCP 26(c)
FORM NO. 2: Notice of Motion for Order Changing Place of Taking Deposition and Payment of Expenses—FRCP 26(c)
FORM NO. 3: Notice of Motion for Order That Deposition Not Be Taken on Ground Will Delay Trial or Harassment—FRCP 26(c)
FORM NO. 4: Notice of Motion for Order to Exclude Persons From Taking of Deposition and That Deposition Be Kept Sealed—FRCP 26(c)
FORM NO. 5: Motion for Protective Order—FRCP 26(c)
FORM NO. 6: Proceedings for Obtaining Protective Order Prior to Deposition—Application for Ex Parte Order and Order Staying Deposition Until Hearing and Determination of Motion—FRCP 26(c)
FORM NO. 7: Joint Motion for Extension of Time Within Which to Complete Discovery—FRCP 26(c)
FORM NO. 8: Motion to Extend Time for Taking of Deposition—FRCP 26(c)
FORM NO. 9: Notice of Motion to Stay Taking of Deposition of Party Until Completion of Taking of Deposition of Other Party—FRCP 26(c)
FORM NO. 10: Motion To Stay Taking of Deposition—FRCP 26(c)
FORM NO. 11: Motion To Bar Further Taking of Deposition on Eve of Trial—FRCP 26(c)
FORM NO. 12: Motion for Protective Order Prohibiting Deposition Where Reasonable Notice Was Not Given—FRCP 30(b)
FORM NO. 13: Motion to Vacate Order Allowing Plaintiff to Serve Notice of Deposition Within 20 Days After Sevice of Summons or Defendant's Appearance—State Practice—California § 2019(b)(1)
FORM NO. 14: Notice of Motion for Order to Limit Scope of Examination—FRCP 26(c)
FORM NO. 15: Motion to Limit Scope of Examination—FRCP 26(c)
FORM NO. 16: Motion for Order that Deposition be Taken on Oral Examination—FRCP 26(c)
FORM NO. 17: Motion That Deposition Be Taken on Written Questions—FRCP 26(c)
FORM NO. 18: Motion to Exclude Persons From Taking Deposition and Keep Deposition Sealed—FRCP 26(c)
FORM NO. 19: Order Excluding Persons From Taking of Deposition and That Deposition Be Kept Sealed—FRCP 26(c)
FORM NO. 20: Order to Show Cause Why Protective Order Should Not Be Granted—Combined With Order Staying Deposition—FRCP 26(c)
FORM NO. 21: Notice of Motion for Order for Simultaneous Exchange of Information—FRCP 26(c)
FORM NO. 22: Motion to Vacate 90 Day Notice—State Practice
FORM NO. 23: Proceedings to Perpetuate Testimony Before Action Is Commenced—FRCP 27(a)(1)
FORM NO. 24: Notice of Taking of Deposition to Perputate Testimony—FRCP 27(a)(2)
FORM NO. 25: Notice of Petition for Order Authorizing Perpetuation of Testimony Before Action is Commenced—State Practice—California § 2017(a)(2)
FORM NO. 26: Order to Show Cause Regarding Deposition Before Action—FRCP 27(a)(3)
FORM NO. 27: Notice of Motion for Order Authorizing Perpetuation of Testimony Pending Appeal—FRCP 27(b)
FORM NO. 28: Affidavit in Support of Motion for Order Authorizing Perpetuation of Testimony Pending Appeal—FRCP 27(b)
FORM NO. 29: Motion for Appointment of Person Before Whom Depositions May Be Taken—FRCP 28(a)
FORM NO. 30: Motion for Commission—FRCP 28(a)
FORM NO. 31: Petition for Issuance of Commission—FRCP 28(a)
FORM NO. 32: Motion for Letter of Request—FRCP 28(b)
FORM NO. 33: Commission to Take the Deposition of a Witness in a Foreign Country—FRCP 28(b)
FORM NO. 34: Letter of Request—FRCP 28(b)
FORM NO. 35: Proceedings for Issuance of Commission or Letters of Request to take Deposition in a Foreign Country—State Practice—California § 2018(b)
FORM NO. 36: Letter of Request—State Practice-Pennsylvania Rule 4015
FORM NO. 37: Stipulation—FRCP 29
FORM NO. 38: Stipulation for Taking of Deposition on Oral Examination—FRCP 29
FORM NO. 39: Stipulation as to Taking of Deposition—FRCP 29
FORM NO. 40: Court Order—FRCP 29
FORM NO. 41: Notice to Take Deposition Upon Oral Examination—FRCP 30(a)
FORM NO. 42: Notice to Take Deposition Upon Oral Examination—FRCP 30(a)
FORM NO. 43: Notice of Motion by Plaintiff for Leave to Serve Notice of Taking Deposition Within 30 Days After Service of Summons or Defendant’s Appearance (and for Order Shortening Time for Notice of Taking Deposition)—FRCP 30(a)
FORM NO. 44: Motion for Order Shortening Time for Notice of Taking Deposition (Presented Without Notice)—FRCP 30(a)
FORM NO. 45: Proceedings by Plaintiff for Orders Allowing Service of Notice of Deposition Within 30 Days After Service of Summons or Defendant’s Appearance and Shortening Time for Notice of Taking Deposition—FRCP 30(a)
FORM NO. 46: Notice of Motion for Order Authorizing Deposition of Prisoner—FRCP 30(a)
FORM NO. 47: Motion for Leave To Take Deposition of Prisoner—FRCP 30(a)
FORM NO. 48: Motion to Vacate Notice to Take Deposition—FRCP 30(b)(1)
FORM NO. 49: Request for Production of Documents at Deposition—FRCP 30(b)(5)
FORM NO. 50: Notice of Taking Deposition on Oral Examination—Corporation, Partnership, Association, or Governmental Agency Deponent—FRCP 30(b)(6)
FORM NO. 51: Notice of Motion for Order Terminating or Limiting Deposition on Oral Examination Which Has Begun—FRCP 30(d)
FORM NO. 52: Motion to Terminate Examination—FRCP 30(d)
FORM NO. 53: Certificate of Officer Before Whom Deposition Is Taken—FRCP 30(f)
FORM NO. 54: Certification of Deposition Taken Before a Notary Public—FRCP 30(f)
FORM NO. 55: Motion to Require Payment of Expenses Where Party Giving Notice Fails to Attend—FRCP 30(g)(1)
FORM NO. 56: Motion to Require Payment of Expenses Where Party Fails to Serve Subpoena—FRCP 30(g)(2)
FORM NO. 57: Cross-Notice to Take Deposition Upon Oral Examination—State Practice
FORM NO. 58: Affirmation in Support of Motion for Deposition of Out-of-State Party—State Practice
FORM NO. 59: Notice of Motion for Deposition of Government Body—State Practice
FORM NO. 60: Notice of Motion for an Order to Produce Certain Material Used by Witness to Refresh Recollection at a Deposition—State Practice
FORM NO. 61: Correction Sheet—State Practice
FORM NO. 62: Letter for Transmission of Transcript to Adversary—State Practice
FORM NO. 63: Notice of Intention to Take Deposition on Written Questions—FRCP 31(a)
FORM NO. 64: Cross-Questions on Written Depositions—FRCP 31(a)
FORM NO. 65: Motion to Suppress Deposition—FRCP 32(b)
FORM NO. 66: Motion to Suppress Deposition for Failure of Witness to Read and Sign Deposition—FRCP 32(b)
FORM NO. 67: Motion to Suppress Deposition Taken by Codefendant—FRCP 32(b)
FORM NO. 68: Written Objections to Errors and Irregularities in Notice of Taking Deposition—FRCP 32(d)(1)
FORM NO. 69: Notice of Motion for Order Suppressing Deposition—FRCP 32(d)(4)
FORM NO. 70: Notice of Motion and Motion to Compel Answers to Questions on Oral Examination—FRCP 37(a)(2)
FORM NO. 71: Notice of Motion for Order Compelling Deponent to Answer Deposition Questions and/or Produce Documents or Other Things at Deposition—FRCP 37(a)(2)
FORM NO. 72: Motion for Order Compelling Deponent to Produce Documents at Deposition FRCP 37(a)(2)
FORM NO. 73: Motion to Compel Answer to Questions in Oral Examination—FRCP 37(a)(2)
FORM NO. 74: Motion to Compel Answer to Questions Propounded Upon Oral Examination (Deposition Taken in District Other Than That in Which Action is Pending)—FRCP 37(a)(2)
FORM NO. 75: Motion to Compel Further Examination—FRCP 37(a)(2)
FORM NO. 76: Motion to Hold Person in Contempt for Failure to Obey Order Compelling Answer—FRCP 37(b)(1)
FORM NO. 77: Motion to Dismiss Action or for Default Judgment for Failure to Comply With Order—FRCP 37(b)(2)
FORM NO. 78: Notice of Motion to Strike Answer of Defendant and to Direct Defendant to Answer Questions and to Award Plaintiffs Costs—FRCP 37(b)(2)
FORM NO. 79: Affirmation in Support of Foregoing Motion to Strike Answer of Defendant, Etc.—FRCP 37(b)(2)
FORM NO. 80: Declaration in Support of Proceedings for Order Imposing Sanctions Based on Refusal to Obey Order to Answer Questions at Deposition—State Practice—California § 2034
FORM NO. 81: Notice of Motion to Strike Answer—FRCP 37(b)
FORM NO. 82: Motion for Sanctions on Failure of Party to Appear for Deposition—FRCP 37(d)
FORM NO. 83: Motion to Strike Complaint and Dismiss Action or Strike Answer and Enter Default Judgement for Failure of Party to Give Deposition—FRCP 37(d)
FORM NO. 84: Motion to Strike Out Complaint and Dismiss Action or Strike Out Answer and Enter Default Judgment for Failure of Party to Give Deposition—FRCP 37(d)
FORM NO. 85: Motion for Sanctions Requiring Payment of Attorney’s Fees and Court Reporter Fees—FRCP 30(g)
FORM NO. 86: Affidavit in Support of Motion to Strike Answer—FRCP 37(d)
FORM NO. 87: Notice of Motion to Compel Examination—State Practice
FORM NO. 88: Notice of Cross-Motion to Compel Testimony—State Practice
FORM NO. 89: Notice of Motion to Strike Case From Trial Calendar—State Practice
FORM NO. 90: Motion for Order Compelling Defendants’ Attendance at Deposition—State Practice
FORM NO. 91: Motion for Arrest for Failure to Comply With Order—State Practice
FORM NO. 92: Motion for Writ of Attachment for Failure to Comply With Order—State Practice
FORM NO. 93: Motion for Rule to Show Cause to Avoid Contempt for Failure to Comply With Court Order—State Practice—Indiana Rule 37
FORM NO. 94: Affirmation in Support of Motion to Compel—State Practice
FORM NO. 95: Subpoena for Deposition for Testimony—FRCP 45
FORM NO. 96: Subpoena to Testify and Produce Documents, Etc., at Deposition—FRCP 45(d)(1)
FORM NO. 97: Motion to Hold Witness in Contempt for Refusal to Comply With Subpoena—FRCP 45(e)
FORM NO. 98: Order to Show Cause—Contempt for Refusal to Comply With Subpoena—FRCP 45(1)
FORM NO. 99: Motion to Quash or Modify Subpoena Duces Tecum—State Practice
(2002)