Rule 6-4 Depositions

(a) Time Limits. The Court may extend any seven-hour deposition period for good cause. See BCR 6-2 (c).

(b) Conduct. Counsel shall conduct depositions as follows:

(1) The parties should cooperate to schedule depositions.

(2) Counsel shall not direct a witness to refrain from answering a question unless —

(A) counsel objects to the question on the ground that the answer is protected by a privilege or another discovery immunity;

(B) counsel proceeds immediately to seek relief under the Civil Practice Act; or

(C) counsel objects to a question that seeks information in contravention of a Court-ordered limitation on discovery.

(3) Objections should be succinct and state only the basis for the objection. Counsel shall not make speaking objections (i.e., argumentative or suggestive in manner).

(4) If counsel defending a deposition believes a question calls for privileged or otherwise protected information, counsel should make a contemporaneous objection without first conferencing "off-the-record" with the witness.

(c) Sanctions. The Court may impose an appropriate sanction for conduct that impedes, delays, or frustrates the fair examination of a deponent. An appropriate sanction for a violation of this rule may include reasonable attorney's fees incurred by any party.

(d) Depositions of Organizations. Depositions of organizations shall proceed as follows:

(1) After a party serves a deposition notice under OCGA § 9-11-30 (b) (6), the named organization to which the notice is issued should present any objections to the noticing party within a reasonable time of service and sufficiently in advance of the deposition.

(2) Counsel for the noticing party and for the named organization to which the notice was issued shall then meet and confer in good faith to resolve any disputes over the topics for the deposition.

(3) The parties shall also discuss and attempt to agree on whether a deponent under OCGA § 9-11-30 (b) (6) may be asked questions about the deponent's personal knowledge. If the parties cannot agree on the appropriate scope of inquiry, the parties shall seek relief from the Court to resolve the dispute prior to the deposition, absent good cause.