(a) Attorneys are expected to make a good faith attempt to clear deposition dates with all other counsel or parties before noting a deposition.

(b) Before agreeing to a deposition date, an attorney should attempt to clear the date with his client if the client is a deponent or wishes to attend the deposition. The same consideration should be extended to any witness the attorney agrees to attempt to produce at the deposition without the need to have that witness served with a subpoena.

(c) An agreed-upon deposition date is presumptively binding. An attorney seeking to change an agreed-upon deposition date should coordinate a new date before changing the agreed date.

(d) If an attorney anticipates requesting that a deponent produce documents, including ESI, at a deposition, the requesting attorney should disclose this request to opposing counsel when attempting to schedule the deposition.

(e) Upon reasonable request and where reasonably practicable, a deponent should produce documents, including ESI, properly requested in a notice of deposition and accompanying subpoena in a reasonable time prior to the deposition. Noncompliance with a reasonable and timely request for production of such documents prior to a deposition may be considered by the Court in a motion or request made pursuant to Rule 2-411(b) to determine whether additional time is needed to fairly examine the deponent.

(f) When more than one individual is designated to testify for an organization pursuant to Rule 2-412(d) without duplication on the designated matter(s) of inquiry, each such individual should be identified in a reasonable period of time before the date of the deposition, as a designated witness along with a description of the matter(s) to which he or she will testify.