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


Summary

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 template includes practical guidance, drafting notes, and alternate and optional clauses. The deposition questions in this template 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. For a full listing of key content covering restrictive covenant considerations, see Restrictive Covenants Resource Kit. 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 ...