{"content":[{"text":"SoloSez Popular Threads, April 2014","bbox":{"left":0.345098,"top":0.043576,"width":0.31000000000000005,"height":0.020984999999999997}},{"text":"Depositions","bbox":{"left":0.427255,"top":0.088242,"width":0.145353,"height":0.03147699999999999}},{"text":"Business/commercial litigation.","bbox":{"left":0.082353,"top":0.151773,"width":0.24823499999999998,"height":0.020212000000000008}},{"text":"1) VIP client is being deposed tomorrow in Texas. Because he is a VIP, two attorneys will be \n accompanying him. Is it okay for both attorneys to object? While it may not be common, is there any rule \n or rationale to prohibit it?","bbox":{"left":0.082353,"top":0.186621,"width":0.828116,"height":0.055061}},{"text":"2) I've heard of things like opposing counsel proposing to stipulate to the \"usual\" stipulations or \n agreements. Any conventional wisdom here? What does that usually include in Texas? Any thoughts? \n Fine to agree or better not to?","bbox":{"left":0.082353,"top":0.256318,"width":0.80047,"height":0.05506}},{"text":"All thoughts welcome. Thanks.","bbox":{"left":0.082353,"top":0.326015,"width":0.24548999999999999,"height":0.020212000000000008}},{"text":"If I was your opposing counsel I would object to having more than one \n attorney object. At trials/hearings, Judges usually don't permit it.","bbox":{"left":0.082353,"top":0.380561,"width":0.5559609999999999,"height":0.03748400000000002}},{"text":"Samuel Katz, New York","bbox":{"left":0.082353,"top":0.432682,"width":0.19254899999999997,"height":0.020212000000000008}},{"text":"I have never heard anyone say anything like that. But, the court reporter will usually ask is this depo \n pursuant to the rules? • I always clarify state or federal rules and say yes.","bbox":{"left":0.082353,"top":0.487227,"width":0.78647,"height":0.037636999999999976}},{"text":"I am sure OC will object to more than one lawyer lodging objections. Depositions should occur as they \n would at trial. A trial judge would never allow more than one lawyer to make objections.","bbox":{"left":0.082353,"top":0.5395,"width":0.808236,"height":0.037636}},{"text":"Tom Crane, Texas","bbox":{"left":0.082353,"top":0.591773,"width":0.14527400000000001,"height":0.020212000000000008}},{"text":"I presume that the depo is taken pursuant to TRCP?","bbox":{"left":0.082353,"top":0.646318,"width":0.404393,"height":0.020212000000000008}},{"text":"It is not common for two attorneys representing the same witness to make \n objections. You can sit next to your partner, and he/she can poke you in \n the leg if he/she thinks you need to object. Under TRCP, you can object \n only to the form of the question and non-responsiveness of the answer, so \n there is not much more you can say other \"objection, form\" (when you are \n defending) and \"objection, non-responsive\" (when you are asking the \n questions).","bbox":{"left":0.082353,"top":0.681167,"width":0.5822350000000001,"height":0.124606}},{"text":"I would not agree to the \"usual stipulations\" unless you know what they \n are. If opposing counsel asks for the first time during the depo, I would \n ask him/her to define them on the record, as different ppl may have \n different ideas on what is \"usual.\" I am not sure what \"usual stipulations\" \n are under TRCP. With that said, I have agreed to stipulations before, e.g. \n in a multiple-defendant case (e.g. mass tort case), I have stipulated that \n 1 of 5","bbox":{"left":0.082353,"top":0.820409,"width":0.573882,"height":0.13471999999999995}}],"images_bbox":[],"images_bbox_not_text_overlap":[]}