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Instead of waiting for the attorney to ask you to prepare for an upcoming deposition or a summary judgment filing, you could start working on those projects well in advance of being asked. For example, after reviewing the new pleadings filed each day, you know that there is a deposition of one of the parties coming up next month.
When it comes to questions and potential issues that the receiving party may have about the discovery process of the producing party, one of the most common and direct methods for conducting "discovery about the discovery" is a deposition under Federal Rule 30(b)(6).
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