Brenda Hillman, et al. v. Gree USA, Inc., et al.

Summary

The United States District Court for the Eastern District of Missouri denied Plaintiffs’ motion to strike errata sheets submitted by three defense experts under Federal Rule of Civil Procedure 30(e). The court held that Rule 30(e) permits changes in form or substance when accompanied by a statement listing the changes and reasons, while emphasizing that the original deposition testimony remains part of the record and may be used for cross-examination.

Holdings

1. Federal Rule of Civil Procedure 30(e), which permits a deponent to make changes in form or substance and provide reasons for those changes, does not impose an extratextual limitation barring substantive or contradictory changes.
2. The challenged errata sheets were not subject to being stricken because the experts made changes in form or substance and signed statements giving reasons for the changes, as required by Rule 30(e).

Questions Presented

1. Whether Federal Rule of Civil Procedure 30(e) permits deponents to make substantive or contradictory changes to their deposition testimony through errata sheets.
2. Whether the challenged expert errata sheets should be stricken because they materially changed the experts' original testimony.

Disposition

other