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Unless it’s something specifically required by local rules, this is nonsense. The instruction not to answer is itself the hook/flag/basis for a later dispute with the court.
Exactly.
Certifying the question for a later dispute before the court.
I've always heard "mark it for a ruling" for this purpose
I use this regularly and am definitely not "old school" by any stretch of the imagination. This may vary state to state, but if your CR knows what they're doing, you'll receive the "certified questions" separately and "certified" by the CR for use in a motion to compel.
Instances involving a deponent refusing to answer, providing evasive/non-responsive answers, or opposing counsel giving non-privilege based instructions to not answer have resulted in sanctions in the form of CR costs and the opportunity to re-depose on their dime.
Mentor
I think it’s easier to get a ruling on the question if certified.