(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.