WL 198445, at *5 (N.D.Ill. Feb.11, 2000) (denying plaintiffs motion to strike deponent’s errata sheet and permitting changes that were “made following ‘recollection refreshed by review of a document’ ”); Titanium Metals Corp. v. Elkem Mgmt., Inc., 191 F.R.D. 468 (W.D.Pa.1998) (rejecting Greenway and stating that courts generally allow deponents to make material changes to prior deposition testimony); Innovative Mktg. & Tech., L.L.C. v. Norm Thompson Outfitters, Inc., 171 F.R.D. 203, 205 (W.D.Tex.1997) (rejecting defendants’ argument that Rule 30(e) only allows “the correction of stenographer/court reporter typographical errors,” calling “[s]uch a reading of the rule ... too narrow”); Hlinko v. Virgin Atl. Airways, No. 96 Civ. 2873(KMW)(THK), 1997 WL 68563 at *2 (S.D.N.Y. Feb. 19, 1997) (<HOLDING>); Lugtig, 89 F.R.D. at 641 (denying motion to
holding that in order to state a claim for ineffective assistance of counsel based on the failure to call a witness to testify the claimant must allege 1 the identity of the potential witness 2 that the witness was available to testify at trial 3 the substance of the witnesss testimony and 4 an explanation of how the omission of the testimony prejudiced the case holding that cjourts generally construe rule 30e broadly to permit any changes to the deposition even those having the effect of contradicting the original answers regardless of how unconvincing the deponents explanation for making the changes might be holding that courts should liberally construe the requirements of rule 3 holding that rule 30e allowed deponent to change the substance of his answers but reconvening the depositions for the limited purpose of inquiring into the reasons for the changed answers and where the changes originated holding that plaintiff entitled to recover for changes not incorporated into contract under theory of breach