N.D. Ohio LR 30.1

(a) Witnesses, parties, and counsel must conduct themselves at depositions in a

temperate, dignified, and responsible manner.

(b) The following guidelines for the taking of depositions emphasize the

expectations of the Court as to certain issues; they are intended to supplement Fed. R.

Civ. P. 26 and 30.

(1) Scheduling. Counsel are expected to make a timely and good faith

effort to confer and agree to schedules for the taking of depositions. Unless

counsel otherwise agree, depositions must be conducted during normal business

hours. Except where good cause exists, no Notice of Deposition or Subpoena can

issue prior to a scheduling conference with opposing counsel. Counsel for the

deponent must not cancel a deposition without stipulation of the examining

counsel or order of the Court.

(2) Decorum. Opposing counsel and the deponent must be treated with

civility and respect. Ordinarily the deponent must be permitted to complete an

answer without interruption by counsel.

(3) Objections. Objections must be limited to (a) those that would be

waived if not made pursuant to Fed. R. Civ. P. 32(d)(3) and (b) those necessary to

assert a privilege, enforce a limitation on evidence directed by the Court or

present a motion under Fed. R. Civ. P. 30(d)(3). No other objections can be

raised during the course of the deposition. In the event privilege is claimed,

examining counsel may make appropriate inquiry about the basis for asserting the

privilege.

(4) Speaking Objections. Speaking objections that refer to the facts of the

case or suggest an answer to the deponent are improper and must not be made in

the presence of the deponent.

(5) Witness Preparation. Preparation of the deponent must be completed

prior to the taking of the deposition. While a question is pending, counsel for the

deponent and the deponent must not confer, except for the purpose of deciding

whether to assert a privilege.

(6) Documents. Examining counsel must provide counsel for the

deponent with copies of all documents shown to the deponent during the

deposition.

(7) Disputes. Counsel must comply with Local Rule 37.1 as to any

disputes arising in connection with the taking of a deposition.