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Perspective

Sep. 5, 2014

When a 'PMK witness' goes off the rails

What should you do when your "person most knowledgeable" witness doesn't work out as planned in a deposition? By Erik Syverson and Scott Lesowitz


By Erik Syverson and Scott Lesowitz


Acme Corporation's attorney sits confidently in the conference room as Acme's "person most knowledgeable," or PMK, witness begins answering the deposition questions. The attorney and the witness had a good pre-deposition meeting, and the witness assured the attorney that he would spend any time needed to review the pertinent documents for the deposition.


But as soon as the substantive questions beg...

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