FKB’s Andrew S. Kowlowitz contributed an article to the Trial Lawyers Section Digest, a publication of the Trial Lawyers Section of the New York State Bar Association. The article provides a primer on the basic rules and guidelines for defending depositions in New York State and Federal courts, and addresses topics such as the scope of allowable questions at a deposition, proper objections under both the CPLR and the Federal Rules, and instances when a witness should be instructed not to answer. The article also addresses new developments in the rules for non-party depositions, which was recently codified in an amendment to CPLR § 3113(c).

A full copy of the article can be found here