FJDCR 11.3

(a) If there are issues regarding the propriety of a question or behavior, the parties must rise above their roles as advocates and attempt in good faith to resolve the issues between themselves, including but not limited to the following:

(1) Remind counsel of FJDCR 11 and give them a copy of the rule, and remind counsel of any other applicable statute, case, or rule.

(2) Take a break to allow emotions to cool.

(3) The attorneys will confer privately to resolve the dispute;

(4) The objecting attorney must concisely, in a non-argumentative, non-suggestive manner, state the objection on the record, cite the applicable statute, case, or rule violated, describe the improper conduct and the actions taken by the parties to resolve the issue.

(5) The other attorney must concisely, in a non-argumentative, non-suggestive manner, state on the record why the objection is not valid, cite the applicable statute, case, or rule, and describe the actions taken by the parties to resolve the issue.

(6) Either or both attorneys may contact the judicial assistant of the assigned judge, or if the judge is not available, the judicial assistant of the other sitting judge, and request a telephone conference to resolve the issue. The attorneys will provide to the judicial assistant the relevant facts regarding the objection, the applicable statute, case, or rule, and a description of what the attorneys have done to comply with this rule and any other actions they have taken to resolve the issue. The judicial assistant will provide the information to the judge who will decide whether to have a telephone conference. In the meantime, the parties will have the court reporter and/or videographer find relevant portions of the record the parties want the judge to consider in resolving the issue.

(7) Finish the examination as to all other topics before suspending or terminating the deposition.

(8) If a written motion regarding the issue is necessary, the parties will provide the court with a transcript or other proof that shows the objected-to question or behavior, and that the attorneys engaged in a meaningful, good faith meet and confer to resolve the issue.