skills/depositions/references/sources.md

# Deposition source references

Use these as method anchors and verify the current forum’s adopted rules, local rules, standing orders, scheduling order, and judge-specific protocol before relying on any federal baseline.

| ID | Source | Use | Status and limitation |
| --- | --- | --- | --- |
| FRCP | [Federal Rules of Civil Procedure](https://www.uscourts.gov/sites/default/files/document/federal-rules-of-civil-procedure.pdf) | Rules 26, 30, 32, 34, 37, and 45: notice, scope, proportionality, documents, 30(b)(6), objections, duration, Rule 30(e) transcript/recording review and changes, transcript use, preservation, nonparty service and fees, place of compliance, protection, enforcement, and transfer | Primary federal authority; current PDF is printed December 1, 2025. Federal baseline only. Rule 30(e) permits changes in form or substance with reasons after a timely review request, but the treatment and consequences of substantive changes require current circuit, state, local, and case-specific research. |
| FRE | [Federal Rules of Evidence](https://www.uscourts.gov/sites/default/files/document/federal-rules-of-evidence.pdf) | Rules 401, 403, 602, 607–613, 801, 803, 804, and 901 as applicable to examination, credibility, recollection, hearsay, and foundation | Primary federal authority; state and other forum evidence rules may differ. |
| MCL | [Manual for Complex Litigation, Fourth Edition](https://www.uscourts.gov/sites/default/files/mcl4.pdf) | Early issue definition, proportional discovery, stable document numbering, exhibit exchange, deposition conduct, preservation planning, and remote ground rules | Federal Judicial Center guidance, not binding law; consult current rules and local orders. |
| FJC | [Civil Litigation Management Manual, Appendix A](https://www.fjc.gov/sites/default/files/2014/civlitig02.pdf) | Practical preparation, transcript use, brief objections, exhibit foundation, and trial designation discipline | Practical judicial guidance, not a universal rule. |
| ABA-508 | [ABA Formal Opinion 508](https://www.americanbar.org/content/dam/aba/administrative/professional_responsibility/ethics-opinions/aba-formal-opinion-508.pdf) | Permissible witness preparation and the boundary between preparation and improper coaching or influence | ABA ethics guidance; check the jurisdiction’s adopted rules and authority. |
| ABA-3.3 | [Model Rule 3.3 comments](https://www.americanbar.org/content/aba-cms-dotorg/en/groups/professional_responsibility/publications/model_rules_of_professional_conduct/rule_3_3_candor_toward_the_tribunal/comment_on_rule_3_3/) | Candor obligations and remedial measures if testimony is false; the rule applies to depositions | Model-rule text is not automatically binding. |
| ABA-3.4 | [Model Rule 3.4](https://www.americanbar.org/groups/professional_responsibility/publications/model_rules_of_professional_conduct/rule_3_4_fairness_to_opposing_party_counsel/) | Fairness to the opposing party and witness-related false-evidence restrictions | Confirm the adopted local text and disciplinary interpretations. |
| ABA-remote | [Remote-deposition protocol guidance](https://www.americanbar.org/groups/litigation/resources/newsletters/trial-evidence/preparing-a-stipulated-protocol-to-govern-remote-depositions0/) | Technology checks, oath, attendance, exhibits, communications, breaks, and troubleshooting | Recommended protocol, not universal law. |

The Federal Rules of Civil Procedure and Evidence are the only primary authorities in this table. The FJC and ABA materials are method and ethics guidance; the skill must label them as such and must not convert them into jurisdiction-neutral legal conclusions.