VII. What constitutes compliance?

Ordinarily a person must first appear for his deposition and then raise any objection to the particular testimony or documentation sought. See Silkwood v. Kerr-McGee Corp., 563 F.2d 433, 437 (10th Cir. 1977). An alternative approach is to request of demand that a deposition be conducted through written interrogatories. See Fed. R. Civ. P. 31. This procedure, which was ordered to be employed by the United States District Court for the District of Colorado in Donohue v. Hoey, Civil Action No. 97-M-2595, allows the reporter's counsel to assert the privilege on a question-by-question basis and permits the Court to determine whether the privilege applies and/or is overcome prior to ordering any response be given.