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 Under Rule 30(d)(2), a court 'may impose an appropriate sanction-including the reasonable expenses and attorney's fees incurred by any party-on a person who impedes, delays, or frustrates the fair examination of the deponent.'


Counsel for both parties 'should strive to be cooperative, practical and sensible, and should turn to the courts (or take positions that force others to turn to the courts) only in extraordinary situations that implicate truly significant interests.' Cable & Computer Tech., 175 F.R.D. 646, 652 (citations and internal quotations marks omitted); see also Saria v. Mass. Mut. Life Ins. Co., 228 F.R.D. 536, 539 (S.D.W. Va. 2005) ('The integrity of the discovery process rests on the faithfulness of parties and counsel to the rules-both the spirit and the letter. [T]he discovery provisions of the Federal Rules are meant to function without the need for constant judicial intervention and ... those Rules rely on the honesty and good faith of counsel in dealing with adversaries.') (quoting Poole v. Textron, Inc., 192 F.R.D. 494, 507 (D. Md. 2000)) (citation and internal quotation marks omitted).

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