Deposition Questions
(Trade Secret Misappropriation and Breach of Restrictive Covenant Action) (Plaintiff Employer to Defendant)


This deposition outline contains essential deposition questions to a defendant in a trade secret misappropriation action and/or a breach of restrictive covenant case—including non-competes, customer and employee non-solicitation agreements, and confidentiality agreements. This form includes practical guidance, drafting notes, and alternate and optional clauses. The deposition questions in this form are provided by way of example only. Each question should be followed with appropriate further inquiry. You should review all rules concerning depositions applicable in the jurisdiction where your case is pending. These annotated deposition questions do not cover all potential state law distinctions concerning restrictive covenants and trade secret protection. You should check any relevant state and local laws. For detailed information on state laws concerning restrictive covenants and trade secrets, see Non-competes and Trade Secret Protection State Practice Notes Chart. For additional ...