Rufolo ex rel. Rossiello v. Midwest Marine Contractor, Inc.

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• noting that “the language describing the breadth of permitted changes has remained essentially unaltered since adoption of the Federal Rules of Civil Procedure in 1937”
• noting that Judge Vratil’s statements in dicta about the limited purpose of Rule 30(e) “give[s] considerable insight into how Rule 30(e) is viewed within the district”
• noting that, under Greenway, “Rule 30(e) only permits correcting transcription errors; therefore, it does not authorize changes because the deponent lied, misspoke, or otherwise wants to change or clarify his testimony,” and that Kansas leans towards this more restrictive view
• “Kansas appears to be one of the federal districts tending toward the more restrictive view of Rule 30(e).”
• “Although these statements [in Garcia] were admittedly dictum when spoken, they have since been elevated and incorporated into the law of this circuit.”
• “A change is material if it bears on an essential element of a claim or defense.” (citing Adler v. Wal-Mart Stores, Inc., 144 F.3d 664, 670 (10th Cir. 1998))

Source: CourtListener parenthetical corpus (CC0).