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DOS and DON’TS of a 30(b)(6) Witness Deposition, Part Five

eDiscovery Daily

2012), objections overruled , 283 F.R.D. But other privileges may be at risk as well, including: Common Interest Privilege. The risk is that work product and other privileges overlapping as case facts become mixed with trial counsel’s mental processes and legal strategies. 8:09-cv-455-T-23TBM (M.D. & Exch.