Checklist · Litigation

"Deposition Day: A Practical Checklist for Counsel and Witness"

Type: Checklist
Jurisdiction: National
Date: 2026-08-09
Topic: Litigation

This checklist is the operational companion to the UpLaw deposition library: not a discussion of doctrine but a sequence of tasks, in the order they must be done, from the decision to notice a deposition through the moment the transcript is put to work in a brief. It runs on a countdown - strategic setup, notice and subpoena mechanics, logistics lock-down, witness preparation, the forty-eight hours before, and the morning of - then splits into three parallel columns for the day itself, because counsel taking, counsel defending, and the witness are each running different jobs at the same table. It supplies the on-the-record openings that should never be improvised, including the stipulations to state and the read-and-sign reservation that is waived by silence, an objection discipline card, a break protocol, and a mid-day audit. Seven contingency checklists cover the situations that derail a deposition: the no-show, the privilege standoff, the abusive examination, the Fifth Amendment invocation, the technology failure, the witness who is coming apart, and the document produced mid-examination. The closing sections address same-day debriefing, the thirty-day transcript window, and the conversion of testimony into admissions, designations, and summary-judgment citations.

Deposition Day: A Practical Checklist for Counsel and Witness

Litigation > Depositions | Published 9 August 2026 | UpLaw - uplaw.us

Depositions are lost to logistics as often as to law: an unreserved read-and-sign, an exhibit nobody pre-marked, a witness who learned the rules the night before. This checklist is the running order - what to do, when to do it, and which items cannot be fixed after the fact.

Keywords: deposition checklist, Rule 30, deposition notice, Rule 45 subpoena, seven-hour limit, stipulations, read and sign, objection discipline, instruction not to answer, Rule 30(d)(3), exhibit protocol, remote setup, witness rules, debrief, errata, Rule 30(e), designations, Rule 32.

How to Use This Checklist

Three audiences share one table and run different jobs. Items are marked accordingly:

[T] — counsel taking the deposition
[D] — counsel defending the witness
[W] — the witness
[ALL] — everyone

Deadlines assume a federal civil case governed by the Federal Rules of Civil Procedure. Local rules, standing orders, and case-specific deposition protocols override these defaults — check all three before relying on any timing item here. For the doctrine behind each step, see Depositions: A Complete Guide for Lawyers and Witnesses; for the preparation curriculum, Preparing a Witness to Testify at Deposition; for forms and decision trees, The Deposition Practice Toolkit.

Items marked ⚠ NOT CURABLE cannot be fixed once the moment passes.

Phase 1 — Strategy and Setup (30+ days out)

[T]

[ ] Identify every witness worth deposing and rank by value; you have a finite number
[ ] Count depositions taken and planned against the presumptive ten per side under Rule 30(a)(2)(A)(i) — the cap is per side, not per party, which routinely surprises multi-defendant groups
[ ] Confirm whether leave of court is required: over ten; a deponent already deposed in the case; before the Rule 26(d) time; a deponent confined in prison
[ ] Decide sequencing — who first, and why. Custodians and mid-level witnesses before decision-makers, so the record is built before the important witness is educated
[ ] Check the discovery cutoff and diary backward: the deposition must be completed, not merely noticed, before it
[ ] Decide whether this witness is an information-gathering deposition or an admissions deposition; they are built differently
[ ] For an organization, decide whether to notice under Rule 30(b)(6), depose individuals, or both
[ ] Consider apex exposure if the target is a senior executive: can the information be had from a subordinate or a designee? Build that record first
[ ] Budget: reporter, transcript, video, travel, expert fees, interpreter

[D]

[ ] Calendar every noticed deposition and identify your witnesses
[ ] Assess whether any deposition warrants a Rule 26(c) protective order — apex, cumulative, disproportionate, or harassing
[ ] For an organizational notice, begin the topic analysis immediately; designee preparation is the long pole
[ ] Identify witnesses who need separate counsel (former employees, employees with individual exposure)

Phase 2 — Notice and Compulsion (21–14 days out)

[T]

[ ] Confirm the local rule's minimum notice period; where silent, 10–14 days is a defensible baseline
[ ] Prepare the Rule 30(b)(1) notice: deponent's name and address (or an identifying description), date, time, place, method of recording
[ ] Serve the notice on all parties
[ ] Choose the recording method deliberately — notice video if there is any realistic chance the witness is unavailable at trial, because a played video is worth many times a transcript read aloud
[ ] For a non-party: prepare and serve a Rule 45 subpoena — a notice alone does not compel a non-party
[ ] Verify the Rule 45(c) place of compliance: within 100 miles of where the person resides, is employed, or regularly transacts business in person. The statewide alternative in 45(c)(1)(B) does not help — subpart (i) reaches only a party or a party's officer, and subpart (ii) applies only to trial attendance, so a true non-party can never be compelled to a deposition beyond 100 miles
[ ] Tender the witness fee and mileage with service
[ ] Serve the subpoena notice on all parties before serving the subpoena itself
[ ] If documents are wanted from a party deponent, remember a Rule 34 request carries its own 30-day response period — do not attach it to a two-week notice and expect production
[ ] For a Rule 30(b)(6) notice: draft topics with reasonable particularity; each topic bounded by subject, time period, and where useful by document set
[ ] ⚠ Conduct the Rule 30(b)(6) conferral required by the rule — before or promptly after service — and memorialize the outcome in writing
[ ] Retain the reporter; confirm availability, remote-oath authority, and rough/expedited transcript pricing

[D]

[ ] Diary the date; confirm the witness's availability immediately and object promptly if the notice is unreasonable
[ ] Serve written objections to notice defects promptly — Rule 32(d)(1) waives errors in the notice that could have been cured if not promptly objected to ⚠ NOT CURABLE
[ ] For a non-party client, evaluate a Rule 45(d) motion to quash or modify on burden, distance, privilege, or trade-secret grounds
[ ] For a 30(b)(6) notice: parse and number every topic; identify overbroad topics; engage in the conferral rather than ignoring it — a refusal to confer is the first paragraph of your opponent's motion

Phase 3 — Logistics Lock-Down (14–7 days out)

[ALL]

[ ] Confirm date, start time, and expected duration in writing with all counsel
[ ] Confirm location or platform, and circulate connection details
[ ] Confirm the reporter and, if applicable, the videographer
[ ] Confirm interpreter needs and qualifications; build in extra time — interpreted testimony runs at roughly half speed and supports a Rule 30(d)(1) request for more hours
[ ] Confirm accommodations for disability, illness, or age, in writing

Remote depositions — stipulate in writing in advance:

[ ] Platform and backup dial-in; what happens to the clock if the connection drops
[ ] Exhibit delivery method: live screen share, shared exhibit platform, or sealed packets mailed in advance and opened on the record
[ ] Who may be present with the witness, and confirmation on the record that no one else is
[ ] Express prohibition on electronic communication with the witness during testimony
[ ] Recording rights and an express prohibition on unauthorized recording by anyone
[ ] Confirmation that the officer may administer the oath remotely, and a stipulation to it ⚠ challenge risk if omitted

[T]

[ ] Assemble and pre-mark exhibits; coordinate numbering with the case-wide convention so Exhibit 14 means the same thing in every transcript
[ ] Prepare a clean exhibit log with Bates ranges
[ ] Draft the outline by objective, not by script: for each module, the admission sought, the foundation to lock first, the documents, the anticipated dodges, and the exit criteria
[ ] Prepare a short opening admonitions block and the stipulations you will propose

Phase 4 — Witness Preparation (10–3 days out)

[D]

[ ] Session One — process and rules (see the preparation guide)
[ ] Provide the witness a written, plain-English rules sheet
[ ] Session Two — chronology, subjects, documents; open questions before closed ones
[ ] Curate the review set deliberately; log what the witness actually reviews, because she will be asked
[ ] Evaluate Rule 612 waiver risk before showing any privileged material to refresh recollection ⚠ NOT CURABLE
[ ] Cover every hard subject, including the worst document in the case
[ ] Ask the catch-all surprise question more than once, in different words
[ ] Session Three — adversarial mock examination, 90+ minutes, with a scored debrief; re-run the three worst moments
[ ] Surface health, medication, and memory issues privately, in advance — never for the first time on the record
[ ] Give conduct instructions: no discussion of the case with anyone else, no social media, no deletion of anything, preservation continuing

[D] — additionally, for a Rule 30(b)(6) designee

[ ] Map every topic to documents, systems, and people
[ ] Perform the inquiry — pull records, query systems, interview current and reachable former personnel; this is a legal duty, and an unprepared designee has been treated as a failure to appear
[ ] Allocate topics across multiple designees where one person's competence will not cover them
[ ] Build the topic binder, tabbed by topic number
[ ] Rehearse the genuine-gap formula: "After reasonable investigation, the company has no information on that"
[ ] Prepare the meta-answers: what did you do to prepare, what did you review, whom did you consult, how long did it take
[ ] Identify likely out-of-scope questions so the capacity objection is ready

Phase 5 — The 48 Hours Before

[T]

[ ] Final outline; mark the three admissions that matter most and make sure they are reachable in the first three hours
[ ] Exhibits final, numbered, loaded into the platform or copied for the room
[ ] Confirm reporter, videographer, room or link, and start time
[ ] Prepare the impeachment materials: prior statements, interrogatory answers, verified pleadings, and prior testimony, tabbed and ready

[D]

[ ] Short logistics-only touch-base with the witness — no new substance
[ ] Confirm the witness knows: location or link, arrival or login time, dress, what to bring (nothing)
[ ] Confirm the protective-order designation mechanics and whether real-time designation is required
[ ] Prepare the objection card (below) and keep it in front of you

[W]

[ ] Sleep. A full night, both nights
[ ] No alcohol the night before
[ ] Do not do a last-minute document binge — it scrambles recall, and you will be asked what you reviewed
[ ] Confirm you have your lawyer's mobile number
[ ] Remote: test camera, microphone, lighting, and connection on the actual platform

Phase 6 — The Morning Of, and Going On the Record

[W] — setup

[ ] Arrive or log in 15 minutes early
[ ] Remote: private room, door closed, alone; desk empty except water; no notes, no phone, no smartwatch, no second screen
[ ] Dress as for a meeting with your banker; solid colors read best on camera
[ ] Eat something. Bring nothing else

[ALL] — before the oath

[ ] Confirm appearances, spellings, and who is attending remotely
[ ] Confirm whether any non-party observer is present and whether anyone objects
[ ] Confirm video recording, if any, and camera framing

[D] — the stipulations block ⚠ do not improvise this

Never agree to "the usual stipulations." There is no such thing, and the phrase means whatever the other side later says it meant. Decline, and state what you do agree to:

[ ] Objections except as to form are reserved to the time of hearing or trial
[ ] Form objections must be stated concisely, consistent with Rule 30(c)(2) and any governing local rule
[ ] Read and sign is expressly RESERVED, not waived — under Rule 30(e) the request must be made before the deposition is completed ⚠ NOT CURABLE
[ ] The officer is authorized to administer the oath remotely (remote depositions)
[ ] Exhibits shown to the witness will be complete documents, absent agreement otherwise
[ ] Any confidentiality designation protocol required by the protective order

[T] — admonitions block

[ ] The oath is the same as at trial, under penalty of perjury
[ ] Verbal answers only; the reporter cannot record a nod
[ ] Let me finish the question; I will let you finish the answer
[ ] Tell me if you do not understand a question; if you answer, I will assume you understood
[ ] Do not guess; label estimates as estimates
[ ] Breaks anytime, but answer a pending question first
[ ] Any medication or condition affecting memory or testimony today?
[ ] Remote only: who else is in the room; what is on your desk; are you communicating with anyone by any means
[ ] For a 30(b)(6): are you the person designated and prepared on each noticed topic; do you understand your answers bind the organization

Phase 7 — During the Day: Counsel Taking [T]

Running the examination

[ ] Track the clock — one day of 7 hours on the record under Rule 30(d)(1); breaks and lunch do not count
[ ] Get the foundational admissions early, before the witness learns your theory
[ ] One fact per question; no compound questions — a compound question yields an ambiguous answer that is useless in a brief
[ ] Funnel: open to exhaust ("What else?" until "That's all"), then close to pin
[ ] Stop after you get the admission. The most common error is one question too many
[ ] Repeat the exhaustion loop before leaving each subject so a new story at trial can be impeached
[ ] Lay foundation for every document before using it for anything that matters
[ ] Do not adopt the witness's vocabulary if it is doing work for the other side; define terms on the record
[ ] Note page/line of every quotable answer as you go, or have a second chair do it

Exhibits

[ ] Mark sequentially; state the exhibit number on the record every time
[ ] Give the witness time to read; a rushed record invites a fair objection
[ ] Confirm the witness has the complete document in front of her

When the defender obstructs

[ ] Ask for the specific ground for any instruction not to answer
[ ] State on the record that the question is being certified for the court
[ ] Note speaking objections and coaching on the record contemporaneously — a clean record is what supports a later motion, and Rule 30(d)(2) reaches anyone who impedes, delays, or frustrates fair examination
[ ] If time is being consumed by obstruction, say so on the record; that is the predicate for additional time under Rule 30(d)(1)

For a 30(b)(6) designee

[ ] Open each topic: "Are you the person designated and prepared to testify on Topic __?"
[ ] Establish preparation efforts — what reviewed, whom consulted, how long
[ ] On key answers, pin: "Is that the organization's position?"
[ ] Where the designee cannot answer, make the failure explicit on the record: the topic number, the question, and the absence of an answer — that is the record for a Rule 37(d) motion

Phase 8 — During the Day: Counsel Defending [D]

The objection card

Situation	Say exactly this
Defective question	"Objection, form." (or the specific ground, if local practice requires)
Two questions in one	"Objection, compound."
Genuinely unclear	"Objection, vague."
Distorts prior testimony	"Objection, mischaracterizes the testimony."
Smuggles in an unproven fact	"Objection, assumes facts not in evidence."
Asks the witness to guess	"Objection, calls for speculation."
Genuine repetition	"Objection, asked and answered."
No personal knowledge shown	"Objection, foundation."
Asks a fact witness to apply law	"Objection, calls for a legal conclusion."
Privileged content	"Objection, attorney-client privilege. I instruct the witness not to answer."
Beyond the noticed topics (30(b)(6))	"Objection, outside the scope of the notice. The witness may answer in his individual capacity."

Discipline

[ ] State the objection. Stop. Do not explain, argue, or elaborate — speaking objections are sanctionable coaching under Rule 30(c)(2)
[ ] Do not object "leading"; leading questions are proper when an opponent examines your witness under FRE 611(c)
[ ] Do not ordinarily object on relevance; it is preserved under Rule 32(d)(3)(A) without an objection
[ ] Instruct not to answer only for privilege, a court-ordered limitation, or to present a Rule 30(d)(3) motion — and state the ground before the instruction
[ ] Instruct sparingly; every instruction is an exhibit for the other side's motion to compel
[ ] Do not instruct on the "did your lawyer tell you what to say" question — the truthful denial is better than the instruction
[ ] Track the clock independently; do not rely on the examiner's count
[ ] Designate confidential testimony as the protective order requires, in real time if required ⚠ possible waiver
[ ] Note every answer that needs correcting; correct on the record the same day

Never

[ ] Confer with the witness while a question is pending ⚠ the one universally condemned practice
[ ] Answer for the witness or "clarify" her answer
[ ] Use an objection to signal an answer
[ ] Spend the word "harassment" on a record that does not support it — you will need it later

Phase 9 — During the Day: The Witness [W]

[ ] Tell the truth. Every time, including when it hurts
[ ] Listen to the whole question — many turn on the last three words
[ ] Pause two beats before every answer, including the easy ones
[ ] Say so if you do not understand: "Can you rephrase that?"
[ ] Answer only the question. Then stop.
[ ] "I don't know" (never knew) and "I don't recall" (cannot retrieve) are complete answers when true
[ ] Estimate only with a real basis, and label it as an estimate
[ ] Read every document completely before answering about it. "I'd like to finish reading the document."
[ ] Avoid always, never, everyone, nothing
[ ] Do not adopt the questioner's characterization: "That's not what I said"
[ ] Correct your own mistakes immediately: "I'd like to correct something I said earlier"
[ ] Stay calm and polite with everyone, all day; anger and friendliness are both techniques
[ ] Do not fill silence — answer, stop, wait
[ ] Resist the lock-in: "That's what I recall as I sit here today"
[ ] Do not argue, ask why a question matters, offer to look things up, or negotiate
[ ] When your lawyer objects: answer anyway, but slow down and re-hear the question
[ ] When your lawyer says "I instruct the witness not to answer": stop. Say nothing. Wait.
[ ] Ask for breaks: "I'd like to take a break when convenient"
[ ] 30(b)(6) only: you speak for the organization; "I don't know" is not available on a noticed topic

Phase 10 — Breaks and the Mid-Day Audit

[ALL]

[ ] Break roughly hourly; fatigue is where errors cluster
[ ] Never break while a question is pending

[D] — at each break

[ ] Check the witness's state honestly; a tired witness needs a longer break, not encouragement
[ ] Note any answer that needs correction on the record
[ ] Confirm the witness is not texting or messaging anyone
[ ] Keep break conversation within proper bounds — expect "did you discuss your testimony during the break?"

[T] — at the lunch break, audit

[ ] Which planned admissions do I have on the record, and at what page/line?
[ ] Which modules remain, and how much clock is left?
[ ] What must I get before I run out of time — and reorder now if necessary
[ ] Which new documents or subjects did the morning open?

Phase 11 — Closing the Record

[T]

[ ] Ask the exhaustion questions on the key subjects one last time
[ ] Confirm every exhibit used is marked and identified on the record
[ ] If time expired over objection, state on the record that the examination is not concluded and the basis for additional time
[ ] Reserve any remaining rights and state whether the deposition is concluded or suspended

[D]

[ ] Confirm read-and-sign is reserved on the record ⚠ NOT CURABLE
[ ] Make any final confidentiality designations required in real time
[ ] Put any needed correction on the record before you go off it
[ ] If suspending under Rule 30(d)(3), state the specific conduct, the ground, and that the deposition is suspended to seek an order — then move promptly

[ALL]

[ ] Confirm transcript delivery timing, format, and whether an expedited copy is ordered
[ ] Confirm exhibit handling — who keeps originals, and how electronic exhibits are transmitted

Phase 12 — Same Day, After

[D]

[ ] Debrief the witness immediately: what was emphasized and in what order (that is a map of the other side's theory); what documents were new; which answers worry the witness; what she recalled during the day that we did not know
[ ] Instruct the witness again: do not discuss the testimony with anyone else
[ ] Note every answer that may need a correction, with your best recollection of the question
[ ] Diary the transcript review window

[T]

[ ] Write the admissions memo while it is fresh — each admission, the subject, and the approximate location
[ ] Note follow-up discovery the deposition opened: documents referenced but not produced, custodians named, systems identified
[ ] Evaluate whether a supplemental Rule 34 request, a further 30(b)(6) topic, or a Rule 37 motion is now warranted
[ ] Reassess case value; deposition performance moves settlement numbers more than any brief

Phase 13 — The Transcript Window

[ALL]

[ ] Calendar 30 days from notice that the transcript is available under Rule 30(e)
[ ] Read the full transcript against your notes

[D]

[ ] Separate transcription errors (correct them) from answers the witness wishes she had given differently (ordinarily, leave them)
[ ] Confirm the governing rule on substantive errata in your circuit before advising any change of substance — the case law is split, and in restrictive jurisdictions contradictory changes may be struck and the original testimony used regardless
[ ] State a reason for every change, as Rule 30(e) requires
[ ] Have the witness sign within the window; a missed window forfeits the correction ⚠ NOT CURABLE

[T]

[ ] Build the page/line digest by topic
[ ] Build the admissions harvest: proposition + citation, formatted for a Rule 56 statement of facts
[ ] Flag every passage worth a designation at trial
[ ] Compare the errata sheet against the original answers — substantive changes are cross-examination material

Phase 14 — Putting the Testimony to Work

[T]

[ ] Deploy admissions in the summary-judgment record with precise page:line citations
[ ] Prepare deposition designations with page:line ranges; anticipate counter-designations under the completeness principle of Rule 32(a)(6)
[ ] Confirm the basis of use: impeachment under Rule 32(a)(2); a party or 30(b)(6) designee for any purpose under Rule 32(a)(3); an unavailable witness under Rule 32(a)(4)
[ ] For video, cut the clips early — editing always takes longer than planned
[ ] Preserve the impeachment sequence for trial: commit, credit the prior statement, confront

[D]

[ ] Prepare counter-designations for completeness
[ ] Identify passages to object to, with grounds, and file within the pretrial schedule
[ ] Prepare the witness for confrontation with her own transcript at trial

Contingency Checklists

The deponent does not appear

[ ] Make a record on the transcript: the notice, the time, the non-appearance, and who is present
[ ] Wait a reasonable period on the record before adjourning
[ ] For a party deponent, evaluate a Rule 37(d) motion — including as against an organization that produced an unprepared 30(b)(6) designee
[ ] For a non-party under subpoena, evaluate contempt under Rule 45(g)
[ ] Preserve costs: reporter, videographer, travel, and attorney time

A privilege standoff

[ ] [D] State the privilege and the instruction plainly; identify enough non-privileged detail — participants, date, general subject — to let the claim be assessed
[ ] [T] Ask for the ground; certify the question; continue with other subjects rather than stopping the day
[ ] [ALL] Confirm whether a Rule 502(d) order is in place before any inadvertent-disclosure fight develops
[ ] Reserve the right to resume on the certified questions if the court orders answers

Abusive or bad-faith examination

[ ] [D] Make a specific, calm record of the conduct — not adjectives, but quoted conduct
[ ] Give the examiner an express opportunity to cure on the record
[ ] Only then suspend under Rule 30(d)(3), stating the ground
[ ] Move promptly; a suspension without a prompt motion is itself sanctionable

Fifth Amendment invocation

[ ] The privilege is asserted question by question, not as a blanket refusal to appear
[ ] [T] Ask each question and obtain each invocation on the record — in a civil proceeding the factfinder may draw an adverse inference, though the invocation supplements other evidence rather than substituting for it
[ ] [D] Consider whether a stay, coordination with criminal counsel, or a protective order is required before the deposition proceeds at all

Technology failure (remote)

[ ] Go off the record while troubleshooting; state the time off and on
[ ] [W] Never answer a half-heard question; never testify about a document you cannot fully see
[ ] Switch to the agreed backup; if the failure is material, adjourn and reset rather than building a defective record
[ ] Note on the record any portion of testimony affected

The witness is coming apart

[ ] [D] Take a break immediately at the next clean seam — answer the pending question first
[ ] Assess honestly: fatigue, illness, or panic
[ ] Consider adjourning by agreement; most opponents will agree, and a defective record helps no one
[ ] Consider a protective order if the examination cannot fairly continue
[ ] Do not let a deteriorating witness improvise on unprepared subjects

A new document appears mid-examination

[ ] [D] Confirm it was produced; if it was not, object on the record and consider whether to permit its use
[ ] [W] Read it completely; say plainly if you have never seen it
[ ] [T] Lay foundation carefully; an unproduced document invites both an objection and a later motion
[ ] [ALL] Note the Bates number, or the absence of one, on the record

Deadline and Limit Quick Reference

Item	Default	Source
Depositions per side without leave	10	Rule 30(a)(2)(A)(i)
Duration	1 day of 7 hours on the record	Rule 30(d)(1)
Notice	"Reasonable written notice"	Rule 30(b)(1)
Non-party place of compliance	100 miles for a deposition; the statewide alternative reaches only parties/party officers, and only trial attendance	Rule 45(c)
30(b)(6) conferral	Before or promptly after service	Rule 30(b)(6)
Transcript review	30 days after notice of availability	Rule 30(e)
Request for review	Before the deposition is completed	Rule 30(e)
Objection to notice defect	Promptly, in writing, or waived	Rule 32(d)(1)
Form objections	Made at the deposition, or waived	Rule 32(d)(3)(B)
Relevance objections	Preserved without objection	Rule 32(d)(3)(A)

Verify each against local rules, the standing order, and any case-specific deposition protocol.

Related UpLaw Resources

Topic	Resource
The complete overview	/documents/article/depositions--a-complete-guide-for-lawyers-and-witnesses
Preparing the witness	/documents/article/preparing-a-witness-to-testify-at-deposition--a-comprehensive-guide
Forms and decision trees	/documents/toolkit/the-deposition-practice-toolkit--rules-objections-forms-and-decision-trees
Taking the deposition	/documents/article/taking-depositions-in-federal-civil-litigation--a-comprehensive-guide
Preparing to take one	/documents/checklist/preparing-to-take-a-deposition--a-practical-checklist
Defending	/documents/article/defending-depositions-in-federal-court--a-comprehensive-guide
Defending on the record	/documents/checklist/defending-the-witness-on-the-record--a-practical-checklist
Life cycle, notice to trial	/documents/toolkit/the-federal-deposition-toolkit--from-notice-to-trial-testimony
Motions to compel and sanctions	/documents/checklist/moving-to-compel-discovery-and-seeking-rule-37-sanctions--a-practical-checklist
Summary judgment	/documents/checklist/moving-for-summary-judgment-under-rule-56--a-practical-checklist

This checklist is general information about litigation procedure, not legal advice, and using it does not create an attorney-client relationship. Deposition practice varies by jurisdiction, court, and judge, and local rules and standing orders override the national defaults reflected here. Consult counsel licensed in the relevant jurisdiction about a specific matter.

Verify Before Publishing

Fed. R. Civ. P. 30(a)(2) leave requirements and the per-side ten-deposition limit
Fed. R. Civ. P. 30(b)(1) notice contents; 30(b)(2) interaction with Rule 34's 30-day period
Fed. R. Civ. P. 30(b)(6) reasonable-particularity and conferral language (December 1, 2020 amendment)
Fed. R. Civ. P. 30(c)(2) objection and instruction language; 30(d)(1) duration and extension; 30(d)(2) sanctions; 30(d)(3) suspension
Fed. R. Civ. P. 30(e) — the 30-day window and the requirement that review be requested before the deposition is completed
Fed. R. Civ. P. 32(d)(1), 32(d)(3)(A), 32(d)(3)(B) — the waiver structure as described
Fed. R. Civ. P. 32(a)(2)–(a)(4), 32(a)(6) — bases for use at trial
Fed. R. Civ. P. 45(c) place of compliance; 45(d) protections; 45(g) contempt
Fed. R. Civ. P. 37(d) — application to an organization producing an unprepared 30(b)(6) designee
Fed. R. Evid. 611(c) (leading), 612 (refreshing recollection), 502(d) (non-waiver orders)
Confirm the statutory witness fee and mileage figures currently in effect before publishing any specific amount (none is stated in this draft — keep it that way or verify)
Confirm the adverse-inference statement against Baxter v. Palmigiano, 425 U.S. 308, 317–18 (1976) — note that Baxter arose from a prison disciplinary hearing and held silence alone insufficient to support an adverse decision
Confirm every internal slug resolves and that article / checklist / toolkit path segments are correct