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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.

 State must provide PMQ in civil case, panel rules
Steven G. Madison, photo courtesy of Quinn Emanuel Urquhart & Sullivan LLP

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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