Eric B. Miller

Document Type



Depositions are an extremely effective and widely used discovery device. Unfortunately, attorneys and litigants seeking to frustrate their opponents often abuse the deposition process by using obstructionist, or “Rambo,” tactics. This Note examines different types of deposition misconduct and the different approaches courts have used to remedy these problems. This Note then looks at deposition misconduct in Connecticut and the sanctioning power of its state courts. Finally, this Note sets forth several suggestions on how to better curb deposition misconduct, including more frequent judicial intervention, greater use of video depositions to provide better evidence of misconduct, and wider observance of the American College of Trial Lawyers Code of Pretrial Conduct.