# Jurisdiction-Specific Adaptations

This skill uses federal rules as the default backbone. When the matter is in state court or subject to local rules, adaptation is required in three main areas: time limits, objection practice, and special doctrines.

Always ask the user to identify the state and provide the relevant state rule or local rule citation. If not provided, proceed using federal defaults but label them as `[FEDERAL DEFAULT — VERIFY FOR JURISDICTION]`.

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## Time Limits

**Federal (default):** One day of seven hours under FRCP 30(d)(1).

**California:** Generally limits depositions to seven hours of total testimony time, with exceptions for experts and complex cases under CCP § 2025.290. Has specific notice-of-video-recording requirements.

**Texas:** Uses a "Level" system (Level 1, 2, or 3) that dictates the total hours allowed for all depositions in a case under Rule 190. The level determines both per-deposition and aggregate limits.

**New York:** Follow Part 221 of the Uniform Rules for the Conduct of Depositions for objection practice rules. Time limits may be set by the court.

Other states vary significantly. When the jurisdiction is unknown, use the federal 7-hour default and flag it prominently.

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## Objection Practice

**Federal:** Under FRCP 30(c)(2), objections must be stated concisely and in a non-argumentative and non-suggestive manner. Speaking objections that coach the witness are prohibited.

**New York:** Part 221 strictly prohibits speaking objections and suggestive interruptions—even more restrictive than federal practice.

**California:** Similar to federal practice but with state-specific procedural code provisions.

**Texas:** Has its own deposition conduct rules. Verify the specific rule for the forum.

The LLM should verify the objection practice rules for the specific forum and incorporate them into the defending pack. Incorrect objection practice creates sanctions risk.

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## Evidence Rules Variations

Evidence rules for refresh and impeachment frequently mirror the Federal Rules of Evidence, but not always.

**FRE 612/613 analogs:** If the matter is in state court, ask whether the jurisdiction follows FRE analogs for Rules 612 (refresh) and 613 (prior inconsistent statements). If unknown, flag for attorney verification and avoid making definitive statements about the state rule.

**Expert admissibility standards:** Federal court uses FRE 702 (Daubert framework, 2023 amendment). Some state courts follow the Frye general-acceptance test rather than Daubert. Do not state which standard applies without jurisdiction confirmation and a verifiable source.

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## Special Doctrines

**Apex doctrine:** Varies by jurisdiction. Some require a showing of unique personal knowledge before allowing deposition of high-level executives. Treat all apex doctrine statements as jurisdiction-dependent. Request the controlling jurisdiction and any relevant protective order precedent.

**Corporate representative practice (30(b)(6) or state analog):** Federal practice under FRCP 30(b)(6) requires the organization to designate persons to testify about information known or reasonably available. State analogs may differ in scope and preparation requirements.

**Deposition limits per case:** Some jurisdictions limit the total number of depositions (federal default: 10 per side under FRCP 30(a)(2)(A)(i)) and some limit aggregate hours across all depositions.

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## General Guidance

When jurisdiction is uncertain:
1. Use federal rules as the default
2. Label every federal-default assumption prominently
3. Ask the attorney to confirm the forum's rules
4. Never assert a specific state standard without verification
5. Include a note: *"This package uses federal rules as defaults. Verify all procedural and evidentiary standards against [jurisdiction] rules before use."*