Mike Thompson: “Yes. I think that without any question it is important that we attempt to have joint participation in the depositions. I…”

“Yes. I think that without any question it is important that we attempt to have joint participation in the depositions. I think that whichever side notices the deposition, there should be a certain period of time when the other side is notified and given the opportunity to attend the deposition. There might be instances where that's impossible, in terms of someone participating, but the notice should always go. The notice should always be there. And we need to have a firm procedure as to who has notices given, so there is no question about the fact that notice has been given. And we need to exercise a little good faith and leeway. If the time that is agreed upon is not fully needed, for example, the side not taking the deposition should not insist on it. If a little more time is needed for scheduling purposes, the side scheduling the deposition should be reasonable there. But I think it is very important, to maintain the credibility of what we are doing, that if at all possible we have both sides at the depositions unless there is an agreement that it is not significant enough a deposition for both sides to be there. So, those are the goals that I would work toward.”