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(a)   Questions About an Asserted Privilege

Counsel may question a deponent who refuses to answer a question on the basis of privilege about information related to the appropriateness of the privilege, including whether:

(1)     the privilege applies under the circumstances;

(2)     the privilege has been waived; and

(3)     circumstances exist to overcome a claim of qualified privilege.

(b)   Private Conference Regarding a Pending Question

Counsel for a deponent may not initiate a private conference with the deponent during the deposition about a pending question except to determine whether to assert a claim of privilege.

(c)   Raising Objections with the Court

A party may recess a deposition to submit an objection by phone to a Judge if the objection:

(1)     could cause the deposition to be terminated; and

(2 )    can be resolved without submitting written materials to the Court.

(d)   Scheduling Depositions

Counsel shall make a good faith effort to schedule depositions in a manner that avoids scheduling conflicts. No deposition will be scheduled on less than 14 days’ notice unless agreed by counsel or the Court orders otherwise.