(2) the material is needed for determination of a pending motion or issue; or
(3) the material is admitted into evidence at a trial or hearing.
(2) any other party can be required to appear for a deposition only where a nonparty witness could be required to appear.
(D) Motions To Compel. A discovery motion must frame the dispute clearly and, if feasible, must, for each discovery request at issue:
(2) quote each objection specifically directed to the discovery request; and
(3) set out the reasons why the discovery should be compelled.
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