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Foreign discovery in state court litigation is never easy. Depositions of non-party witnesses in other states can require a commission in another state. Depositions of non-party witnesses in other countries can require adherence to international discovery law. These rules may slow discovery, but they make sense because they do not apply to the parties themselves. Parties can be compelled to attend deposition by simple notice, wherever they reside. Code Civ. Proc. §§2026.010, 2027.010.
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