Deposition Question & Subpoena Formulation
FRCP 26(b)(1) & Rule 30 Standards
E.g., "When did you first engage in intimate physical relations with the defendant, and what dates were personal vacations booked prior to legal separation?"
Proportionality & Evidentiary Factors
Rule 26 & 30 Deposition Diagnostic Assessment
Live Dynamic Evaluation
Proportionality Score
64%
Relevance Ratio
70%
Privacy Intrusion
85%
| Rule Standard | Compliance | Judicial Rationale |
|---|
Recommended Counsel Posture & Motions
Deposition Room Protocol: Object on the record under Rule 30(c)(2) as to relevance, privacy, and harassment. Under standard federal rules, counsel may NOT instruct a witness not to answer unless asserting a recognized evidentiary privilege (or enforcing a court-ordered limitation). If inquiry persists into intimate non-financial acts, counsel must preserve the objection and immediately notice a Motion for Rule 26(c) Protective Order or suspend under Rule 30(d)(3).