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A software company sued a former engineer in federal court for misappropriation of trade secrets. The company noticed 14 oral depositions without seeking leave of court. At the engineer's deposition, company counsel questioned him for seven hours. Defense counsel repeatedly made lengthy objections suggesting answers, and instructed the engineer not to answer questions about nonprivileged meetings because counsel thought the questions were irrelevant and harassing. The company then demanded a second full day of deposition, arguing that defense counsel had consumed much of the first day with objections.
The company also served 32 numbered interrogatories. Several numbered interrogatories contained multiple unrelated subparts, including requests to identify every person with knowledge, every communication, every document, and every damages theory. The engineer objected to the number of depositions and interrogatories, refused to answer beyond 25 interrogatories, and moved for a protective order. The company moved to compel and for sanctions.
How should the court rule on the deposition and interrogatory disputes? Discuss the numerical and time limits, the instructions not to answer, the speaking objections, and any appropriate sanctions or discovery-management relief.