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have all of your depositions been taken with leave of court?

"Rule 30. Deposition by Oral Examination

(a) When a Deposition May Be Taken.

(1) Without Leave. A party may, by oral questions, depose any person, including a party, without leave of court except as provided in Rule 30(a)(2). The deponent�s attendance may be compelled by subpoena under Rule 45."

why wouldn't you subpoena them to compel them to appear?



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