In the wake of California state court budget cuts, avoiding and resolving discovery disputes without court assistance is a necessary skill. Here are some suggestions for new lawyers on how to prevent or address conflict as you gear up to take your first depositions.
Do your best to accommodate the schedules of witnesses and opposing counsel. If time constraints force you to serve the deposition notice without having a date agreed on with opposing counsel, serve the notice with a cover letter that offers to reschedule.
