What action should a client take if they do not want to answer invasive questions during a deposition within the scope of the discovery plan?

When a client is faced with invasive questions during a deposition that fall within the scope of the discovery plan, the appropriate action is to instruct the client not to answer and to move for a protective order. This approach recognizes the client’s right to limit the disclosure of sensitive information while also taking formal steps to protect their interests.

Choosing to instruct the client not to answer is grounded in the principle that certain questions may violate privacy rights or could be unduly burdensome. A protective order can be sought from the court, which allows the client to address the issue in a structured legal environment. This means that the objection can be formally stated, and the matter can be resolved through judicial means, rather than risking the client inadvertently disclosing detrimental information.

This response ensures that the client is acting within their legal rights while preserving the integrity of the deposition process. It's also important to note that ignoring the questions or agreeing to answer with a stipulation could lead to negative consequences for the client, including potential waiving of their right to object later on or inadvertently providing harmful testimony.