Objections must be brief and cannot suggest answers to witness.

Deposing counsel must instruct witness to ask them for clarifications during deposition.

Most objections are preserved and should not be made during deposition.

Counsel cannot instruct witness not to answer except for privilege or court limitations.

Private off-the-record conferences prohibited except for privilege decisions.

Private conferences are subject to inquiry for witness-coaching.

Private conferences must be noted on record with purpose and outcome.

Deposing counsel must provide document copies to witness counsel before or during deposition.

One question at a time; witness must fully answer before next question.

No argument with opposing counsel; objections noted and witness answers.

Witness/counsel must advise if unclear and permit rephrasing; no argument about questions.

Examining counsel must not interrupt witness answering questions.

No unnecessary recitation or lengthy quotations from discovery materials.

Non-compliance may result in sanctions including civil contempt and attorney fees.