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If the deponent did not bring requested documents, what should I do/say at the depo?
If the deponent lies that s/he doesn't have the documents , can I file motion to force production after the depo?
Isn't a "subpoena duces tecum" applies to nonparty? I will be deposing the other party who is the plaintiff and whom I requested to produce documents.
Should I make it an exhibit on any documents (deponent's or mine) that I will question deponent with?
I will question plaintiff on some allegations in his Complaint, can I just read the allegations on the complaint without making it an exhibit?
What is the appropriate way to address myself in a question that involve me? Do I refer myself as first person or third person? For example, "When did you meet me?" or "When did you meet defendant?" or "When did you meet so-and-so?
I don't understand what you mean by 'to avoid artificiality in your questions'. Can you give an example of aritificiality.
I mean don't try to speak in legalese. Just use plain English and speak the way you would in an normal conversation. For someone not practiced in depositions, using legal terminology will likely trip you up. So for example, when you are referring to yourself, say "me" instead of "defendant".
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