Carolyn Elefant at writes here with a critique of the Seventh Circuit decision  in Redwood, that lacked a practical, common sense approach to problems encountered with obstreperous lawyers in a deposition. (Here is a prior blog post I did on the case.) Though not condoning boorish behavior, she noted that the panel deciding the case, while undoubtedly smart and capable jurists, did not have much experience, if any, with the rough and tumble schoolyard realities of a deposition, and the increased (and perhaps prohibitive) cost if a depostion were stopped in order to file a motion to compel, or for a protective order,  under Rule 30(d), every time a lawyer taking or defending a deposition violated the rules (along with the uncertainty of when the motion would be heard and how long it would be before the deposition were rescheduled–as it is not always possible to get a judge on the phone during the deposition.) For Delaware cases on point regarding deposition practice, see the Delaware Supreme Court’s famous decision in Paramount Communications, Inc. v. QVC Network, Inc., 637 A.2d 34, n.28 (Del. 1994) and also a Delaware Superior Court decision in State v. Mumford, 731 A.,2d 831, 835 (Del. Super. 1999).