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Each party may have no more than six20 hours in total to examine and cross-examine all witnesses in oral depositions. The parties may agree to expand this limit up to ten hours in total, but not more except by court order. The court may modify the deposition hours so that no party is given unfair advantage.
A party may take the testimony of any person or entity by deposition on written questions before any person authorized by law to take depositions on written questions. A notice of intent to take the deposition must be served on the witness and all parties at least 20 days before the deposition is taken.
P. 30(a)(2)(ii), which provides that a witness may not be deposed more than once absent a stipulation or leave of court.
Whereas depositions are useful for obtaining candid responses from a party and answers not prepared in advance, interrogatories are designed to obtain accurate information about specific topics. Interrogatories can be quicker, less costly, and less complicated than depositions, but there are downsides.
Rule 92. General Denial (1985) A general denial of matters pleaded by the adverse party which are not required to be denied under oath, shall be sufficient to put the same in issue.