I. Introduction

Attorneys experienced in defending depositions know the importance of witness preparation. A key component of this process requires counsel to sift through large amounts of produced discovery to identify specific documents ripe for examination by opposing counsel. An interesting issue unfolds when an examining attorney asks a witness during the deposition to recount

At the time In re XTO Energy (In re XTO Energy, Inc., 2018 WL 2246216 (Tex. App.-Houston [1st Dist.]) was decided by the 1st Court of Appeal in May of 2018, Texas Appeals Courts had already issued a slew of cases in preceding years that looked very favorably upon defendant forum non conveniens