Government,
California Courts of Appeal
Jul. 8, 2025
State must provide PMQ in civil case, panel rules
A California appellate court ruled that district attorneys must produce a person most qualified for deposition in civil enforcement cases, rejecting arguments that prosecutors are shielded from standard discovery obligations.




For the first time, a California appellate court has published a decision on whether the state must produce for deposition a person most qualified to testify on its behalf, and said the answer is yes.
The 4th District Court of Appeal panel rejected the state's argument - made through Riverside, Los Angeles, Santa Clara and San Diego County district attorneys - that its person most qualified (PMQ) is its own counsel and cannot be deposed.
"We're grateful that ...
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