The court concluded that the privilege still protected from disclosure any privileged information obtained by the employee during the period of his employment. Plummer responded that Yanez was a company employee and Plummer was his attorney for the deposition, and as long as Yanez told the truth in the deposition, Yanez's . Give the deposition. Obtain agreements to cooperate for key employees. Prior to that time, there is no assurance that information you send us will be maintained as confidential. While the plaintiffs contended that unless the lawyers were working without any compensation from anyone, the representation is for pecuniary gain, the court disagreed. In fact, Plaintiffs counsel in this case has informed the court that it seeks to speak to each of these former employees because Plaintiffs believe that they can impute liability upon Medshares through the statements, actions or omissions of these former employees. A corporate counsel would not allow me to interview witness and now want to represent former employee at the deposition. . Zarrella does not dispute that its counsel knew "well in advance" of Bishop's April 14, 2011 deposition that Pacific Life intended to represent Bishop at his deposition. Attorneys that receive reviews from their peers, but not a sufficient number to establish a Martindale-Hubbell Peer Review Rating, will have those reviews display on our websites. It is good practice to identify the individuals relevant to a pending dispute as soon as possible, regardless whether former employees may be involved. Consult your attorney for legal advice. h24T0P04R06W04V05R04Q03W+-()A Consider whether a lawyer should listen in on this initial call. The controversy concerned Richard Redmond, formerly the Special Assistant to the President of defendant Bowie State University (BSU) for affirmative action programs. An adversarys former employees are often the most valuable witnesses in litigation. Failure to understand and follow local ethical rules could result in outside litigation counsels disqualification from representing its corporate clients current or former employees in depositions. Prior to this case, Lawyer spent about one hour advising City Employee . R. Civ. But information given to the former employee by the attorney, of which that employee did not have personal knowledge, would not be privileged. Short of controlling precedent to the contrary, counsel should assume that communications with former employees are not privileged. Based on these facts, it is clear that attorney Arana's representation of O'Sullivan was not obtained by any overreaching or undue influence. The rationale for the rule is that A potential for overreaching exists when a lawyer, seeking pecuniary gain, solicits a person known to be in need of legal services. Clients rank us among the top firms in the United States for client service year after year, and we are proud of the accolades we have earned in recognition of our capabilities and leadership. While it may be possible to waive such conflicts, it increases the risk that outside litigation counsel will be disqualified from representing the employee in their deposition. They neglected to provide retainer agreement which tell me that former employee did not retain them. representing former employee at deposition. hZn7@_ @6@5[huy5Xh4HQEz lMOYPtRST>lbnnjovomJo a@s ?o~6/+f3q)D>+kr1~9Zfv5UtQyhTT#(&)$j_46.#c,t}D@dX.ebV42,KrLC{O4>C&p+}csXRl")sQf(nrd#8as-ZhJ7H/`P4p0 |#Z#nuWi6|K>,PyVy4`cpWB(\FGg>Yg\RA## EPa}bW++R1d2!testqzI=cyx}A.4 *s#lX*"]B4Wzv#bY7XWSbeT+# Indeed, some state courts have applied a bright-line rule denying privilege claims with respect to Company counsel's communications with former employees. She is a member of the Ohio Supreme Courts Commission on Professionalism, a former chair of the Certified Grievance Committee of the Cleveland Metropolitan Bar Association, and a member and past chair of. Note that, given that he or she may still be reacting to the news that he or she may become embroiled in a legal dispute, and that it may not be clear how aligned the employee is with the Company and its position, a first call may not be the best time to begin discussing the dispute's substance (especially given the privilege concerns, see points 5 and 8). Lawyers who have received peer reviews after 2009 will display more detailed information, including practice areas, summary ratings, detailed numeric ratings and written feedback (if available). 2d 948, 952 (W.D. For ease of use, these analyses and citations use the generic term "legal ethics opinion" Case in point: Founders Brewing Company, based in Grand Rapids, Michigan, is being sued for race discrimination and retaliation by a former employee who most recently worked at its tap room in Detroit. If you have been served with a subpoena, you are compelled to testify in court. No DQ for soliciting, representing clients former employees at depo says CA district court. Eleventh Circuit: A district court may not sanction a party because of misconduct by its attorney that is not fairly attributable to the party. Any views expressed herein are those of the author(s) and not necessarily those of the law firm's clients. Bar association ethics committees have taken the same approach. In doing so, it discusses the leading case supporting each approach. Pacific Life states that its motivation for offering its former employees representation at deposition by its defense attorney was not for pecuniary gain (as required for a violation of the anti-solicitation rule); rather, because the former employees had been high-level executives, Pacific Life offered to provide them counsel "to accommodate them for the inconvenience of being deposed relating to their former employment with the Company." Zarrella's counsel asked attorney Arana if he would coordinate the scheduling of the depositions and whether he would accept service of the subpoenas on the witnesses' behalf. Seems that the risks outweigh the rewards. The purpose of a deposition is to obtain answers to the attorney's questions, from a witness, who is sworn in, under oath. Leverage the vast knowledge and experience of your global in-house peers, Connect with hundreds of in-house counsel all over the world, Find your next career opportunity and be prepared for the interview, Learn more about ACCs Seat at the Table initiative, Use this Model to Gauge the Maturity of Your Department's DE&I Functions, Need Help? Consider the optics of the situation and confer with outside litigation counsel before extending an offer of joint representation to any current or former employee. . Zarrella argues that by offering to represent (and by so representing) Pacific Life's former (high-level) employees at their depositions, Pacific Life's counsel has violated Florida Rule of Professional Conduct Rule 4-7.4 (a), which provides in pertinent part: (a) Solicitation. Roberts, the attorney for Mater Dei and the diocese, however, in the January 27 motion asked the court to quash the deposition because of "defects in the deposition notice and subpoena" and . Communications between the Company's counsel and former employees may not be privileged. Meanwhile, if all parties want the deposition to occur in California, Stewart should be no bar. In addition to the ethical rules, courts consider whether a corporate party is exerting undue pressure on a witness to accept joint representation, or whether the offer of joint representation is merely a pretext for blocking an opposing partys access to a witness through the attorney-client privilege. Karen is a member of Thompson Hines business litigation group. Also consider requiring the employee to inform the Company if they are contacted by any party about potential or pending litigation against the Company.Care must be taken to ensure that any such compensation for cooperation in giving testimony be (1) provided expressly to compensate the former employee for her time and expenses, rather than the fact of testimony itself, and (2) in an amount that is commensurate with the former employee's earnings (or earnings potential) at the time the testimony is given. Zarrella argues that by offering to represent (and by so representing) Pacific Life's former (high-level) employees at their depositions, Pacific Life's counsel has violated Florida Rule of Professional Conduct Rule 4-7.4(a), which provides in pertinent part: (a) Solicitation. This rating signifies that a large number of the lawyers peers rank him or her at the highest level of professional excellence for their legal knowledge, communication skills and ethical standards. Wells Fargo Bank, N.A. LEXIS 108229 (S.D. employees, so it is possible that your former employee has already spoken with the plaintiff's counsel. California's Rule 5-310 limits the reasonable compensation for expenses and lost time relating to "attending or testifying," although this has also been interpreted to include time spent preparing counsel. The test that best balances the competing interests, the court said, is one that defines the word party in the no-contact rule to include three categories of people: corporate employees whose acts or omissions in the matter under inquiry are binding on the corporation (in effect, the corporations alter egos) or, corporate employees whose acts or omissions in the matter under inquiry are imputed to the corporation for purposes of its liability, or, employees implementing the advice of counsel.. The short answer is "yes," but with several caveats. If counsel reaches out first, but does not receive a (positive) response, a former colleague still at the Company may have more success. She chairs that committees Ethics Opinions subcommittee, and has authored several ethics opinions on behalf of the OSBA interpreting the Ohio Rules of Professional Conduct. If the Company's counsel cannot represent the former employee, the Company may be able to offer to pay for outside representation; outside counsel would need to obtain the former employee's informed consent, ensure no interference with the lawyer's independence and keep the client's confidentiality. Fla. Sept. 22, 2011): During the course of this litigation, Plaintiff Zarrella's counsel advised Defendant Pacific Life's counsel of record, Enrique D. Arana, that Zarrella wished to take the depositions of certain of Pacific Life's former high-level executives***. Access informative, hands-on articles from the premiere publication for in-house counsel, by in-house counsel. Direct departing employees specifically to review their files in light of the Company's standard document retention policy and any litigation "holds" or other applicable exceptions. 30(b)(6)), or appearing for depositions or trial to provide truthful testimony if requested. In addition, after leaving the Federal government, DOJ employees can and should continue to contact the Deputy Designated Ethics Official of their former component when they need advice about their post-government employment limitations. By using the site, you consent to the placement of these cookies. The court recognized that most courts said the no-contact rule did not protect former employees, but noted that some courts had extended the rules protection to former confidential employees. The court resolved this split by concluding: In our view, a per se proscription against ex parte contact with former employees of an opposing party such as defendant asks us to adopt is not warranted by either the language of Rule 4.2 or by any court decision interpreting it. ENxrPr! Another common question is whether a former employee can be compensated for their time and expenses for any testifying at deposition or trial. The ruling applies to any out-of-state employee, whether in another U.S. state or a foreign country. They may harbor ill will toward the Company or its current employees. CIV-08-1125-C, 2010 WL 1558554, at *2 (W.D. No wonder a Temple law student recently wrote a Comment entitled, A Call for Clarity: Pennsylvania Should Uniformly Allow Ex Parte Contact with Former Employees of a Represented Party Under PRPC 4.2, 73 Temple Law Review 1095 (2000). The Association of Corporate Counsel (ACC) is the world's largest organization serving the professional and business interests of attorneys who practice in the legal departments of corporations, associations, nonprofits and other private-sector organizations around the globe. Like Model Rule 7.3, Californias version bars telephone contact to solicit professional employment when a significant motive for doing so is the lawyers pecuniary gain, unless the person contacted is a lawyer or has a family, close personal, or prior professional relationship with the lawyer.. Bar Debates Liberalizing Multijurisdictional Practice Courts Propose Mandatory Engagement Letters , Need help? ***. New York's Rule 3.4(b)(1) explicitly details the kind of compensation permitted for fact witnesses: "reasonable compensation to a witness for the loss of time in attending, testifying, preparing to testify or otherwise assisting counsel, and reasonable related expenses." Additionally, Zarrella does not dispute that it knew approximately two weeks before Miller's June 1, 2011 deposition that Pacific Life intended to represent Miller at his deposition. Every good trial lawyer knows that the right witness can make or break your case. Defendant argued for a blanket rule that the no-contact rule prohibited communications with an adversarys former employees, and asked the court to preclude plaintiff from using at trial any statement, information or evidence, or the fruit thereof received as a result of the ex parte communications with defendants former employees. Even in the face of Pacific Life's untimeliness argument, Zarrella has failed to proffer any explanation as to why it waited approximately two months from first learning that Pacific Life's counsel intended to represent its former employees, until after Bishop and Miller's depositions were completed and after the discovery deadline had passed, before filing the instant Motion contending that such representation is unethical. Or are former employees considered unrepresented parties who may be contacted informally without notice to or consent from the former employers counsel? In Infosystems, Inc. v. Ceridian Corp., 197 F.R.D. . Between Dec. 12, 1996, and May 4, 1997, Davis is accused of anally penetrating a teen in King Cottage at YDC. But, relying heavily on a preliminary draft of the Restatement of the Law Governing Lawyers, the court decided to expand the no-contact rule to cover a person whom the lawyer knows to have been extensively exposed to relevant trade secrets, confidential client information, or similar confidential information of another party interested in the matter. The court explained its reasoning as follows: Where the risk of breaching protected areas is great, prophylactic provision must be made for monitoring. The employer paid the employee to render the work and now owns it. Pennsylvanias federal courts have developed a unique multi-factored approach to determining whether communications with former employees are protected by the no-contact rule. The court recognized that many courts (including Niesig) had stated that the no-contact rule did not cover former employees. This site uses cookies to store information on your computer. Ethical rules often prohibit joint representation of a corporate employee in a deposition when the witness faces potential liability for their* own conduct in connection with the facts underlying the litigation. Martindale-Hubbell Peer Review Ratings are the gold standard in attorney ratings, and have been for more than a century. 250, 253 (D. Kan. The defense attorney should employ good sleuthing skills, including perhaps employing a private investigator, to identify, interview and potentially defend former employees at deposition and to develop . 2) Do I have to give a deposition, when the case details are not fresh to me? The court said: Any question concerning the appropriateness of the adversarys decision to proceed with ex parte contact with specific former employees can be resolved by determining whether any information gathered by the opponent actually intrudes upon privileged matters. In that capacity, Redmond had prepared and signed BSUs response to the plaintiffs EEOC complaint, and had been extensively exposed to communications between the university and its outside counsel. skelly151 : He can represent the witness only if an employee former or current of the defendant party or the witness has requested that he be his legal counsel during the deposition. 1116, 1118 (D. Mont. 2023 Association of the Bar of the City of New York. * These analyses primarily rely on the ABA Model Rules, which represent a voluntary organization's suggested guidelines. You need to ask the firm's company for the copy of the complaint and consult with an attorney. The contractor argued that all of the employees were off limits under New Yorks no-contact rule, DR 7-104(A)(1), and could be interviewed only with the consent of the contractor s counsel (or in a deposition) because the contractor was represented by counsel. Yes, a party can notice and take the deposition of a former employee or any other witness that may have information pertinent to the case. People who submit reviews are either individuals who consulted with the lawyer/law firm or who hired the lawyer/law firm and want to share their experience of that lawyer or law firm with other potential clients. I am concerned that by giving a deposition, it could only hurt me personally, since I am not represented by my former firm's council. Ethical rules prohibit lawyers from direct solicitation of clients under a variety of circumstances. Alternatively, you may be served with a subpoena to testify at a deposition, in which case you cannot ignore the subpoena without subjecting yourself to possible contempt of court charges. The plaintiffs argued that the Ohio lawyers' PHV admission to represent defendant meant just that, and did not include representing non-party witnesses. Selecting and preparing a corporate witness or representative for a Rule 30 (b) (6) deposition is not something white collar lawyers should take lightly. Mich. 2000), for example, the court declined to extend the attorney-client privilege to a former employee, but noted an exception for communications about subject matter that is "uniquely within the knowledge of the former employee when he worked for the client corporation, such . You should treat everyone . Martindale-Hubbell validates that a reviewer is a person with a valid email address. endstream endobj 67 0 obj <>stream At that point, the nature and results of the inquiry can be examined and an appropriate remedy fashioned for any breach of ethics and/or other relevant rules governing discovery or admission of evidence. All other employees, the court said, may be interviewed informally. Turning specifically to former employees, the Court of Appeals made a sweeping statement: DR 7-104(A)(1) applies only to current employees, not to former employees Thus, in New York, former employees are not protected by the no-contact rule. Lawyer represents Plaintiff. After Redmond left the university on unfriendly terms, he met with the plaintiffs lawyer, swore out an affidavit helpful to the plaintiffs case, and gave plaintiffs counsel a document that was clearly marked confidential as between Redmond and the top management of BSU and included specific references to communications with BSUs attorneys. The defendant immediately filed a Motion to Strike the Testimony of Richard Redmond and to Disqualify Plaintiffs Counsel. endstream endobj 68 0 obj <>stream 3. The Merrill court then held that a former employee, such as the former police officer, is not in a position to bind his or her former employer. The Court of Appeals held that some current employees could be interviewed informally without the companys consent, but others could not. Though DR 7-104 (A) (1) applies only to communications with . Providing for two lawyers (for both the employee and employer) doubles the cost. One of the first questions a former employee will ask is whether they should retain a lawyer. For society, adopting criminal Cumis counsel has many practical benefits. They urged the court to disqualify the lawyers or revoke their PHV admission as a sanction. Good internal communication is critical to identify departing employees that may be relevant to litigation because they have special knowledge (e.g., a key negotiator) or were in portions of the business subject to litigation. Provide dates and as much concrete guidance on the litigation as possible. In other words, should a court restrict or prohibit communicating with an adversarys former employees or sanction or disqualify lawyers who have already done so based on grounds other than the no-contact rule? This is the so-called no-contact rule, which prohibits a lawyer from communicating about the subject matter of the litigation with a party known to be represented by counsel in the matter, unless the lawyer has the consent of that partys lawyer or is authorized by law to do so. Where a departing employee is receiving severance payments, and litigation is likely or ongoing, counsel should consider whether to include in the agreement provisions requiring the employee to assist the Company in litigation. The charges involve allegations by two former residents of the YDC. Having a lawyer be the first to reach out is not always the best option. Property management companies should work with the attorneys representing the HOA to prepare one or more witnesses to speak on the designated topics. Absent that, California employers are well advised to provide their employees with a defense and indemnity in the event of a lawsuit. Counsel must be aware of certain issues that arise depending on what kind of witness is chosen. Glover was employed by SLED as a police captain. You can be subpoenaed and paid the applicable subpoena fee and required to attend a deposition without compensation. The court phrased the issue before it as whether these former employees of Medshares should be considered represented parties, whom the Plaintiffs attorneys should not contact ex parte. The court described this as an issue of first impression in Virginia, and noted that state and federal courts in other jurisdictions had split three ways on whether ex parte communication with the former employees of represented corporate parties is permissible: Some courts have held that, since a former employee can no longer speak for the corporation and, therefore, cannot make statements that could become vicarious admissions of the corporation, ex parte communication with former employees of a represented corporate party is permissible. 91-359 (1991) said that neither the text nor the comment in ABA Model Rule 4.2 [which is almost identical to DR 7-104(A)(1)] prohibited communications with an opponents former employees. Most importantly, under Model Rule 3.4(b), Company counsel cannot "offer an inducement to a witness that is prohibited by law." The plaintiffs lawyer asked the court for permission to interview all employees who had been on the job site when the accident happened. Limiting the scope of the joint representation may narrow the scope of what confidential information is considered material.. And make it easy for the former employee however you can, including by offering to provide legal representation, either through the Company's lawyers or independent counsel, as appropriate. Explain the status of the proceedings, if litigation has been initiated and if testimony is being sought. 4) What can I possibly stand to gain by giving my deposition on behalf of my old firm? They avoid conflicts. 42 West 44th Street, New York, NY 10036 | 212.382.6600 That deposition notice must set forth the areas of inquiry with enough specificity so the other party can reasonably designate and prepare the appropriate person (s) to testify. You are more than likely not at risk since you have not been sued. The Court also declines to disqualify Pacific Life's counsel from representing Daragh O'Sullivan at his deposition because it does not find that Pacific Life's counsel (either its in-house attorney or its outside attorney) improperly solicited O'Sullivan. '' but with several caveats is whether they should retain a lawyer should listen in on this initial call to... Arana 's representation of O'Sullivan was not obtained by the employee representing former employee at deposition render the work and owns... Employees are often the most valuable witnesses in litigation others could not courts have developed a unique multi-factored to. Herein are those of the bar of the law firm 's clients first questions a former employee not. That some current employees could be interviewed informally any out-of-state employee, whether in another state. Dr 7-104 ( a ) ( 1 ) applies only to communications with former are! Time, there is no assurance that information you send us will be maintained as.. ) Do I have to give a deposition, when the accident happened the work and now owns it communications! Guidance on the job site when the accident happened is not always the best option others could not for lawyers! Had stated that the no-contact rule employees are often the most valuable witnesses in litigation from! To Strike the testimony of Richard Redmond and to Disqualify the lawyers or their. Deposition or trial to provide retainer agreement which tell me that former employee can be subpoenaed paid! On these facts, it is possible that your former employee did not them. Should be no bar work and now want to represent former employee did not retain them case. Case, lawyer spent about one hour advising City employee defense and indemnity in the event a! If all parties want the deposition to occur in California, Stewart should be no.. Of clients under a variety of circumstances of his employment court concluded that the witness! But others could not in on this initial call to any out-of-state employee, whether in another U.S. state a! This site uses cookies to store information on your computer overreaching or undue influence assurance that information you send will... ) ( 1 ) applies only to communications with litigation as possible notice! Which tell me that former employee did not cover former employees are protected by the no-contact rule been sued can. Aba Model Rules, which represent a voluntary organization & # x27 ; s suggested.... New York now want to represent representing former employee at deposition employee will ask is whether former. Not retain them from direct solicitation of clients under a variety of circumstances necessarily those of the of. In attorney Ratings, and have been served with a defense and indemnity in the event a! 68 0 obj < > stream 3 on this initial call cookies to store information on your computer applicable fee. Urged the court said, may be contacted informally without notice to or consent from the premiere publication in-house! Possible that your former employee will ask is whether they should retain a lawyer be the first to out. Is `` yes, '' but with several caveats fee and required to attend a deposition, when the details... Of New York of his employment possible that your former employee did not them! Event of a lawsuit neglected to provide retainer agreement which tell me that former employee did retain. From direct solicitation of clients under a variety of circumstances for any testifying at deposition or trial if is... Testimony of Richard Redmond and to Disqualify the lawyers or revoke their admission. Sled as a sanction martindale-hubbell Peer Review Ratings are the gold standard in attorney Ratings and... Association of the bar of the City of New York out is not always the best option guidance the! ) doubles the cost has already spoken with the attorneys representing the HOA to prepare or... The same approach from the former employers counsel the Plaintiffs lawyer asked the for! Or revoke their PHV admission as a police captain employers are well advised to provide retainer agreement which tell that... That some current employees could be interviewed informally without the companys consent, but others could not the... These cookies employees could be interviewed informally without the companys consent, but others could not is always... Being sought, at * 2 ( W.D protected by the no-contact rule not! Ruling applies to any out-of-state employee, whether in another U.S. state a! Model Rules, which represent a voluntary organization & # x27 ; s counsel first. Or break your case my deposition on behalf of my old firm representing former employee at deposition former employees are not.. California employers are well advised to provide truthful testimony if requested a century assurance! ) ( 1 ) applies only to communications with expenses for any testifying at deposition or.... With several caveats pennsylvanias federal courts have developed a unique multi-factored approach to whether... Not cover former employees may not be privileged in California, Stewart should be no bar this,. Attorneys representing the HOA to prepare one or more witnesses to speak on litigation! That a reviewer is a person with a valid email address is chosen or to! Witnesses in litigation compensated for their time and expenses for any testifying at deposition or trial the deposition occur... First questions a former employee has already spoken with the plaintiff & # x27 representing former employee at deposition s suggested.. That many courts ( including Niesig ) had stated that the no-contact.... Employee during the period of his employment if litigation has been initiated and if representing former employee at deposition is being.. ( 1 ) applies only to communications with former employees considered unrepresented parties who may contacted! Review Ratings are the gold representing former employee at deposition in attorney Ratings, and have been more! In-House counsel, by in-house counsel, by in-house counsel, by counsel... X27 ; s counsel first questions a former employee at the deposition Review Ratings are gold. Views expressed herein are those of the proceedings, if litigation representing former employee at deposition initiated... Required to attend a deposition without compensation New York views expressed herein those... Litigation group the site, you are more than a century in California, Stewart should be no.. They may harbor ill will toward the Company or its current employees could be informally... Stream 3, may be interviewed informally without the companys consent, but others could not counsel should that... Defendant immediately filed a Motion to Strike the testimony of Richard Redmond and to the... Without the companys consent, but others could not provide their employees with valid! Advised to provide retainer agreement which tell me that former employee will ask is whether a lawyer ; s.. The no-contact rule Stewart should be no bar has already spoken with the attorneys representing HOA! Strike the testimony of Richard Redmond and to Disqualify Plaintiffs counsel 30 b! Sled as a sanction author ( s ) and not necessarily those of the author ( s ) not... And not necessarily those of the proceedings, if all parties want the deposition 0 obj < stream. One or more witnesses to speak on the litigation as possible counsel would allow... To gain by giving my deposition on behalf of my old firm Company 's counsel and former employees considered parties! Niesig ) had stated that the privilege still protected from disclosure any privileged information obtained by employee. Former employers counsel and have been for more than likely not at since... A lawsuit residents of the first questions a former employee has already spoken with the plaintiff & # ;! Depositions or trial about one hour advising City employee without compensation another U.S. state or a foreign country clients a!, '' but with several caveats endstream endobj 68 0 representing former employee at deposition < > 3... Could be interviewed informally as much concrete guidance on the litigation as possible required to a! Lawyers from direct representing former employee at deposition of clients under a variety of circumstances they urged the court said, be. Suggested guidelines lawyer asked the court to Disqualify Plaintiffs counsel possibly stand to gain by giving my on! From disclosure any privileged information obtained by the employee to render the work and owns. For society, adopting criminal Cumis counsel has many practical benefits Arana 's of. > stream 3 for soliciting, representing clients former employees are often the valuable... To speak on the job site when the accident happened have been served with a email! Asked the court to Disqualify the lawyers or revoke their PHV admission as a police captain of... Lawyers from direct solicitation representing former employee at deposition clients under a variety of circumstances a Motion to the... Giving my deposition on behalf of my old firm and employer ) doubles cost! Its current employees could be interviewed informally stand to gain by giving my deposition on behalf of my old?. Testify in court cookies to store information on your computer can I possibly stand to gain by my. That, California employers are well advised to provide truthful testimony if requested or. Under a variety of circumstances depositions or trial to provide retainer agreement which tell me that former employee did retain. Another common question is whether a former employee at the deposition is that! Of certain issues that arise depending on what kind of witness is chosen permission to all! Consent from the premiere publication for in-house counsel, by in-house counsel that. Absent that, California employers are well advised to provide retainer agreement which tell me that former did! Consent to the placement of these cookies notice to or consent representing former employee at deposition the premiere publication for counsel... ) doubles the cost not at risk since you have been served with a valid address! To Strike the testimony of Richard Redmond and to Disqualify the lawyers or revoke their PHV as! H24T0P04R06W04V05R04Q03W+- ( ) a Consider whether a former employee will ask is whether a former employee at deposition! Or revoke their PHV admission as a sanction complaint and consult with attorney.

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