Imagine this: You are defending a civil suit in which your client, an accounting firm, has been sued by a plumbing supply company for damages in excess of $20 million. According to the plaintiffs, your client failed to detect and disclose to its management the fact that its trusted former controller had been embezzling company funds for years.

You have reason to believe that this former employee possesses information that may prove invaluable to your client, and you elect to elicit such testimony during a deposition. You serve a subpoena and begin arduous deposition preparation.

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