POPULARITY
Learning Objectives:By the end of this series, listeners should be able to:Understand the research expectations of PICU Fellows in the United States.Explain the types of research available to PICU fellows and how a new fellow might explore their local options. Explain the work necessary to refine a research question and write mature specific aims for a project. Understand the key factors involved in getting a fellowship paper submitted, including the common pitfalls for each type of research About our Guest: Mike Spaeder is a Professor of Pediatrics at the University of Virginia (UVA) School of Medicine and a pediatric critical care physician at the UVA Children's Hospital in Charlottesville, Virginia. He received his bachelor's degree in mathematics from Trinity College and his master's in statistics from George Washington University, where he also received his medical degree. He completed his pediatrics residency at Hasbro Children's Hospital/Brown University and his pediatric critical care fellowship at the Johns Hopkins Hospital. He is now the director of the Pediatric Critical Care fellowship at the UVA Children's Hospital. His research is based at the Center for Advanced Medical Analytics at the University of Virginia, where he focuses on modeling physiologic signatures of illness to identify patients at risk for clinical deterioration. Selected References:Horvat CM, Hamilton MF, Hall MW, McGuire JK, Mink RB Child Health Needs and the Pediatric Critical Care Medicine Workforce: 2020-2040. Pediatrics 2024 Feb 1 153Tasker RC. Writing for PCCM: The 3,000-Word Structured Clinical Research Report. Pediatr Crit Care Med. 2021 Mar 1;22(3):312-317.Sanchez-Pinto, L. Nelson MD, MBI1; Badke, Colleen M. MD, MS1; Pololi, Linda MBBS, FRCP (hon)2. Group Peer Mentoring: A Strategy to Promote Career Development and Improve Well-Being Among Early-Career Faculty in Pediatric Critical Care Medicine. Pediatric Critical Care Medicine ():10.1097/PCC.0000000000003763, May 15, 2025. | DOI: 10.1097/PCC.0000000000003763 Scott K. Radical Candor: Be a Kick-Ass Boss Without Losing Your Humanity. New York: St. Martin's Press; 2017. 1st ed. Equator Guidelines: https://www.equator-network.org/For Authors : Pediatric Critical Care MediQuestions, comments or feedback? Please send us a message at this link (leave email address if you would like us to relpy) Thanks! -Alice & ZacSupport the showHow to support PedsCrit:Please complete our Listener Feedback SurveyPlease rate and review on Spotify and Apple Podcasts!Donations are appreciated @PedsCrit on Venmo , you can also support us by becoming a patron on Patreon. 100% of funds go to supporting the show. Thank you for listening to this episode of PedsCrit. Please remember that all content during this episode is intended for educational and entertainment purposes only. It should not be used as medical advice. The views expressed during this episode by hosts and our guests are their own and do not reflect the official position of their institutions. If you have any comments, suggestions, or feedback-you can email us at pedscritpodcast@gmail.com. Check out http://www.pedscrit.com for detailed show notes. And visit @critpeds on twitter and @pedscrit on instagram for real time show updates.
Liz Lightstone, MBBS (Hons), PhD, FRCP - Preventing Flare and Protecting Function: What Progress Is Being Made in Active Lupus Nephritis?
Adam Brufsky, MD, PhD / Rebecca Dent, MD, FRCP (Canada) - Same Class, Different Agents: Practical Considerations for Managing Toxicities of Interest in Patients on TROP2-Directed Therapies in Breast Cancer
Adam Brufsky, MD, PhD / Rebecca Dent, MD, FRCP (Canada) - Same Class, Different Agents: Practical Considerations for Managing Toxicities of Interest in Patients on TROP2-Directed Therapies in Breast Cancer
Adam Brufsky, MD, PhD / Rebecca Dent, MD, FRCP (Canada) - Same Class, Different Agents: Practical Considerations for Managing Toxicities of Interest in Patients on TROP2-Directed Therapies in Breast Cancer
Liz Lightstone, MBBS (Hons), PhD, FRCP - Preventing Flare and Protecting Function: What Progress Is Being Made in Active Lupus Nephritis?
Adam Brufsky, MD, PhD / Rebecca Dent, MD, FRCP (Canada) - Same Class, Different Agents: Practical Considerations for Managing Toxicities of Interest in Patients on TROP2-Directed Therapies in Breast Cancer
Liz Lightstone, MBBS (Hons), PhD, FRCP - Preventing Flare and Protecting Function: What Progress Is Being Made in Active Lupus Nephritis?
Adam Brufsky, MD, PhD / Rebecca Dent, MD, FRCP (Canada) - Same Class, Different Agents: Practical Considerations for Managing Toxicities of Interest in Patients on TROP2-Directed Therapies in Breast Cancer
Liz Lightstone, MBBS (Hons), PhD, FRCP - Preventing Flare and Protecting Function: What Progress Is Being Made in Active Lupus Nephritis?
Adam Brufsky, MD, PhD / Rebecca Dent, MD, FRCP (Canada) - Same Class, Different Agents: Practical Considerations for Managing Toxicities of Interest in Patients on TROP2-Directed Therapies in Breast Cancer
Marianna Fontana, MD, PhD / Julian Gillmore, MD, PhD, FRCP, FRCPath - Identifying Outcomes That Matter in ATTR-CM: Critical Considerations in the Interpretation of Contemporary Clinical Trials
Marianna Fontana, MD, PhD / Julian Gillmore, MD, PhD, FRCP, FRCPath - Identifying Outcomes That Matter in ATTR-CM: Critical Considerations in the Interpretation of Contemporary Clinical Trials
Marianna Fontana, MD, PhD / Julian Gillmore, MD, PhD, FRCP, FRCPath - Identifying Outcomes That Matter in ATTR-CM: Critical Considerations in the Interpretation of Contemporary Clinical Trials
Marianna Fontana, MD, PhD / Julian Gillmore, MD, PhD, FRCP, FRCPath - Identifying Outcomes That Matter in ATTR-CM: Critical Considerations in the Interpretation of Contemporary Clinical Trials
Marianna Fontana, MD, PhD / Julian Gillmore, MD, PhD, FRCP, FRCPath - Identifying Outcomes That Matter in ATTR-CM: Critical Considerations in the Interpretation of Contemporary Clinical Trials
Marianna Fontana, MD, PhD / Julian Gillmore, MD, PhD, FRCP, FRCPath - Identifying Outcomes That Matter in ATTR-CM: Critical Considerations in the Interpretation of Contemporary Clinical Trials
Despite decades of effort and innovation since the groundbreaking To Err is Human report over 25 years ago, preventable harm in healthcare persists, and violence against healthcare workers continues to rise. With record understaffing, burnout, mandatory overtime, and mounting documentation demands, the pressure to provide safe care has never been higher nor the stakes more urgent. In this first episode of our new series focusing on safety in healthcare, we explore a bold shift toward "total systems safety" with two leaders at the forefront of this movement who know these challenges all too well. Patricia McGaffigan, RN, MS, CPPS, Senior Advisor for Patient and Workforce Safety at the Institute for Healthcare Improvement, and President of the Certification Board for Professionals in Patient Safety, and Donald Berwick, MD, MPP, FRCP, President Emeritus and Senior Fellow at the Institute for Healthcare Improvement, and former Administrator of the Centers for Medicare and Medicaid Services. Together, they continue to shape national safety efforts including IHI's Safer Together: National Action Plan to Advance Patient Safety the first public-private collaboration of its kind. Spearheaded by McGaffigan and bringing together 27 major organizations that had never collaborated before. The plan aims to restructure the very foundation of healthcare, building safety into every level of the system around four interlocking pillars. Leadership & Governance: Strong, visible leadership and policies that make safety a strategic priority. Workforce Safety & Well-Being: Protecting nurses and healthcare workers – physically and mentally – so they can care safely for others. Patient & Family Engagement: Partnering with patients and family caregivers as co-designers of safe care. Learning Systems: Creating feedback loops and continuous improvement so lessons from one hospital spread everywhere. At the heart of this movement is a truth long understood by nurses: safety is not a checklist or a policy, it's a culture, a commitment, and a collective responsibility. As Patricia McGaffigan reminds us, “You can't have patient safety if you don't have a safe workforce.” And as Don Berwick warns, “The illusion that safety is a matter of individual effort is one of the most toxic notions in the whole safety enterprise. It is we, not me.” Nurses have always led by example, holding space for healing while navigating broken systems. Now, their leadership is essential in building the future of healthcare safety: one that protects not only patients, but the people who care for them. Where healthcare is not only safer, but also is a culture that ensures we're all Safer Together.
In this episode, Dr Gideon Hirschfield meets with patient advocate Jess Schnur to discuss challenges related to the diagnosis and management of primary biliary cholangitis (PBC) to provide actionable strategies for healthcare professionals to incorporate into patient care, including:Disease concerns and frequently asked questions from a patient perspectiveManaging symptomsTreatment options and supportive careImportance of awareness and educationPresenters:Gideon Hirschfield, MA, MB BChir, FRCP, PhDLily and Terry Horner Chair in Autoimmune Liver Disease ResearchProfessor, Division of Gastroenterology and HepatologyUniversity of TorontoDirector, The Autoimmune and Rare Liver Disease ProgrammeDirector, Francis Family Liver ClinicToronto General Hospital, University Health NetworkOntario, CanadaJess N. Schnur, BSN-RNNational PBC Patient AdvocateAmerican Liver FoundationDonation Support Services CoordinatorLifeline of OhioColumbus, OhioTo learn more, see the programHear Me: Patient Perspectives on PBC
This month, we're digging into some recent, clinically notable HIV research in the U.S. that leaves us seeing a complex mix of clouds and silver (or perhaps gold?) linings. Specifically: new findings on ART prescription practices; a study on barriers to rapid HIV treatment initiation; and state-level data on PrEP prescribing trends relative to HIV diagnoses. Support us by visiting the online transcript: https://www.thebodypro.com/podcast/hiv/future-hiv-care-clouds-silver-linings-june-2025 And watch this touching video from Oslo Pride on the importance of symbols: https://www.youtube.com/watch?v=UVepoXddTW4 The pod production team: Our co-hosts are Laura Waters, M.D., FRCP, and Myles Helfand; our senior production manager is Alina Mogollon-Volk; our senior producer is Lizzie Warren; our associate production manager is Maui Voskova; our audio editor is Kim Buikema; and our executive producer is Myles Helfand.
Peter Schmid, FRCP, MD, PhD - Use of Neoadjuvant Chemoimmunotherapy Followed by Adjuvant Immunotherapy in Early-Stage TNBC: A Case-Based Discussion
In this episode of the Cancer Assist Podcast, Dr. Bill Evans sits down with Dr. Peter Ellis, medical oncologist at the Juravinski Cancer Centre, to talk about the incredible changes in lung cancer care. Once considered one of the most hopeless diagnoses, lung cancer treatment has drastically changed, with targeted therapies, immunotherapy, and personalized care offering patients more options and longer lives than ever before. Dr. Ellis shares what patients need to know about diagnosis, treatment choices, and why there's real reason to feel hopeful.----DisclaimerThe Cancer Assist Show is hosted by Dr. Bill Evans, MD, FRCP, Past President of the Juravinski Hospital and Cancer Centre at HHS. Brought to you by the Cancer Assistance Program—an organization lending support to cancer patients and families of those affected by cancer. --- The Cancer Assist Show and its content represent the opinions of Dr. Bill Evans and guests to the podcast. Any views and opinions expressed by Dr. Bill Evans and guests are their own and do not represent those of their places of work. The content of The Cancer Assist Show is provided for informational, educational and entertainment purposes only, and is not intended as professional medical, legal or any other advice, or as a substitute or replacement for any such advice. The Cancer Assist Program, Dr. Bill Evans and guests make no representations or warranties with respect to the accuracy or validity of any information or content offered or provided by The Cancer Assist Show. For any medical needs or concerns, please consult a qualified medical professional. No part of The Cancer Assist Show or its content is intended to establish a doctor-patient or any other professional relationship. This podcast is owned and produced by the Cancer Assistance Program.
International Scientific Association for Probiotics and Prebiotics (ISAPP)
This episode features Prof. Emad El-Omar MD FRCP from the University of New South Wales in Sydney, Australia, speaking about a recent paper exploring the healthy microbiome concept, as well as the latest research on how the gut microbiome contributes to the pathophysiology of several diseases. Prof. El-Omar talked about research on H. pylori-induced disease […] The post Progress in understanding the gut microbiome's role in health and disease states, with Prof. Emad El-Omar MD FRCP appeared first on International Scientific Association for Probiotics and Prebiotics (ISAPP).
Richard David Graham Leslie, MD, FRCP, FAoP - When Could Dysglycaemia in Adults Be Type 1 Diabetes? Expert Perspectives on Recognising and Addressing Diagnostic Complexities and Challenges
Richard David Graham Leslie, MD, FRCP, FAoP - When Could Dysglycaemia in Adults Be Type 1 Diabetes? Expert Perspectives on Recognising and Addressing Diagnostic Complexities and Challenges
Richard David Graham Leslie, MD, FRCP, FAoP - When Could Dysglycaemia in Adults Be Type 1 Diabetes? Expert Perspectives on Recognising and Addressing Diagnostic Complexities and Challenges
Richard David Graham Leslie, MD, FRCP, FAoP - When Could Dysglycaemia in Adults Be Type 1 Diabetes? Expert Perspectives on Recognising and Addressing Diagnostic Complexities and Challenges
Richard David Graham Leslie, MD, FRCP, FAoP - When Could Dysglycaemia in Adults Be Type 1 Diabetes? Expert Perspectives on Recognising and Addressing Diagnostic Complexities and Challenges
Richard David Graham Leslie, MD, FRCP, FAoP - When Could Dysglycaemia in Adults Be Type 1 Diabetes? Expert Perspectives on Recognising and Addressing Diagnostic Complexities and Challenges
What happens when a classically trained physician opens the door to the invisible?In this captivating episode, Dr. Bernard Beitman sits down with Dr. Anona Blackwell, a highly respected genitourinary physician whose clinical contributions have changed medical practice in the UK—including three publications in The Lancet. But behind the lab coat lies a healer with deep intuitive insight.Dr. Blackwell shares remarkable stories from her career, where patients were accompanied not just by symptoms, but by spiritual presences—deceased loved ones, spirit animals, even Archangel Michael. These weren't hallucinations or fabrications—they were transformative experiences that helped patients heal.From a scientific background in biophysics to mystical awareness in practice, Anona takes us on a journey that challenges the divide between evidence and energy. Together, she and Bernie explore how intuition, synchronicity, and unseen forces can be felt in the body, recognized in the clinic, and validated by physicians who dare to say: "Yes, your experience is real."Order Dr. Beitman's newest book "Life-Changing Synchronicities: A Doctor's Coincidences and Serendipities" at Simon & Schuster, Barnes and Noble, Inner Traditions, Amazon, Books-a-Million, Bookshop.org (May 2025).About Dr. Anona Blackwell:Anona Blackwell, BSc, AKC, FRCP, is a retired Genito-Urinary physician and author of From Medic to Mystic, a memoir chronicling her paranormal experiences throughout a distinguished medical career. With a degree in Cell Biology/Biophysics from King's College London and a medical degree from Westminster Medical School, she became internationally recognized for her work on vaginal infections, eventually holding a consultant post in Swansea. Her mystical experiences have long informed her approach to clinical care, blending science with spirit.Dr. Blackwell's Book "From Medic to Mystic" About Dr. Bernard Beitman:Dr. Beitman is the first psychiatrist since Carl Jung to seriously study coincidences. He is the founder of The Coincidence Project and the author of Connecting with Coincidence and Meaningful Coincidences. He received his psychiatric training at Yale and Stanford and has served as Chair of Psychiatry at the University of Missouri-Columbia
In a time of growing uncertainty for the HIV response within the U.S., you may be wondering: What do I do if the public guidelines and resources I rely on to provide HIV-related clinical services cease receiving updates or are permanently removed? Laura and Myles discuss the complexities of our current moment -- and the extent to which our colleagues across the pond in the British HIV Association (BHIVA) can help fill the gap. Laura will also review recent highlights from BHIVA's annual Spring Conference, a cross-disciplinary meeting featuring clinical research and state-of-the-art updates. ° Read the full transcript, which includes a bevy of relevant links: https://www.thebodypro.com/podcast/hiv/future-hiv-care-bhiva-may-2025 ° The pod production team: Our co-hosts are Laura Waters, M.D., FRCP, and Myles Helfand; our senior production manager is Alina Mogollon-Volk; our senior producer is Lizzie Warren; our associate production manager is Maui Voskova; our audio editor is Kim Buikema; and our executive producer is Myles Helfand.
Chronicling her dual professional life as a highly respected, Lancet-published academic physician while also investigating powerful psychic and paranormal experiences in her work and personal life, Dr. Blackwell presents compelling evidence for telepathy, clairvoyance, near-death experiences (NDEs), life after death, the power of prayer, non-ordinary reality, and more.The book reveals how, after years of attempting to reconcile her extraordinary experiences, Dr. Blackwell transformed from a scientifically trained medic into a mystic, acknowledging there is far more to life - and to us - than science alone can explain. Her irreverent sense of humour (her account of meeting Prince Charles is unmissable) and her ability to integrate both orthodox and complementary medical practices create a thought-provoking, multi-layered, and often amusing read.By sharing her forays into non-ordinary reality, Dr. Blackwell encourages others to share their paranormal experiences without fear of being labelled ‘crazy'.BioFrom humble beginnings as the daughter of a bus driver and market gardener, growing up on a smallholding in rural Wales, Dr. Blackwell, BSc, AKC, FRCP, rose to become a leading authority in genito-urinary medicine. Immersed in orthodox medicine by day, she devoted her after-hours to the in-depth investigation of anomalous phenomena, energy healing, and metaphysics. Her innate psychic abilities offered profound insights into her patients' lives, psyches, and hidden traumas – insights that few modern doctors are privileged to experience.A passionate explorer of the natural world, with a deep-rooted interest in organic gardening, sustainable living and the mysteries of the cosmos, with years of experience in both scientific research and metaphysical studies, Dr. Blackwell shares her unique perspectives and knowledge through engaging blog posts. Her mission is to inspire others to appreciate the wonders of our universe, from the soil beneath our feet to the stars above. You can read more fascinating stories about her own and others' experiences at Dr Blackwell's website, where she encourages those who have had similar experiences to share them with her audience.https://www.amazon.com/dp/B0DV9KZSY5https://www.drblackwell.co.uk/ https://www.pastliveshypnosis.co.uk/https://www.patreon.com/ourparanormalafterlifeMy book 'Verified Near Death Experiences' https://www.amazon.com/dp/B0DXKRGDFP
Chronicling her dual professional life as a highly respected, Lancet-published academic physician while also investigating powerful psychic and paranormal experiences in her work and personal life, Dr. Blackwell presents compelling evidence for telepathy, clairvoyance, near-death experiences (NDEs), life after death, the power of prayer, non-ordinary reality, and more.The book reveals how, after years of attempting to reconcile her extraordinary experiences, Dr. Blackwell transformed from a scientifically trained medic into a mystic, acknowledging there is far more to life - and to us - than science alone can explain. Her irreverent sense of humour (her account of meeting Prince Charles is unmissable) and her ability to integrate both orthodox and complementary medical practices create a thought-provoking, multi-layered, and often amusing read.By sharing her forays into non-ordinary reality, Dr. Blackwell encourages others to share their paranormal experiences without fear of being labelled ‘crazy'.BioFrom humble beginnings as the daughter of a bus driver and market gardener, growing up on a smallholding in rural Wales, Dr. Blackwell, BSc, AKC, FRCP, rose to become a leading authority in genito-urinary medicine. Immersed in orthodox medicine by day, she devoted her after-hours to the in-depth investigation of anomalous phenomena, energy healing, and metaphysics. Her innate psychic abilities offered profound insights into her patients' lives, psyches, and hidden traumas – insights that few modern doctors are privileged to experience.A passionate explorer of the natural world, with a deep-rooted interest in organic gardening, sustainable living and the mysteries of the cosmos, with years of experience in both scientific research and metaphysical studies, Dr. Blackwell shares her unique perspectives and knowledge through engaging blog posts. Her mission is to inspire others to appreciate the wonders of our universe, from the soil beneath our feet to the stars above. You can read more fascinating stories about her own and others' experiences at Dr Blackwell's website, where she encourages those who have had similar experiences to share them with her audience.https://www.amazon.com/dp/B0DV9KZSY5https://www.drblackwell.co.uk/ https://www.pastliveshypnosis.co.uk/https://www.patreon.com/ourparanormalafterlifeMy book 'Verified Near Death Experiences' https://www.amazon.com/dp/B0DXKRGDFP
Myles Helfand and Laura Waters, M.D., FRCP, discuss recently published, clinically noteworthy findings from a trio of venerable HIV cohort studies. First, they review new data from the ATHENA study on non-AIDS events among so-called "HIV controllers." They then move on to recent findings from the START study regarding the link between ART initiation timing and cardiovascular disease risk. Finally, they explore new REPRIEVE data exploring the impact (or lack thereof) of statin use on non-cardiovascular events. ‡ Read (and share!) the full transcript: https://www.thebodypro.com/hiv/future-hiv-care-nuances-matter-april-2025 ‡ The pod production team: Our senior production manager is Alina Mogollon-Volk; our senior producer is Lizzie Warren; our associate production manager is Maui Voskova; our audio editor is Kim Buikema; and our executive producer is Myles Helfand.
In this episode, Chloe Orkin, MBChB, FRCP, MD, and Jean-Michel Molina, MD, PhD, discuss highlights from CCO's independent conference coverage of CROI 2025, including:Advances in HIV treatment based on results from CARESPotential HIV therapies in the pipeline, such as doravirine/islatravirEffects of broadly neutralizing antibodies on HIV treatment and cure Key clinical data on HIV and STI prevention obtained from PILLAR, HPTN 083, PURPOSE 1, and STOMPPresenters:Chloe Orkin, MBChB, FRCP, MDProfessor of Infection and InequitiesDean for Healthcare TransformationHonorary Consultant Physician, Barts Health NHS TrustFaculty of Medicine and DentistryQueen Mary University of LondonLondon, United KingdomJean-Michel Molina, MD, PhDProfessor of MedicineUniversity of Paris CiteDepartment of Infectious DiseasesSaint-Louis and Lariboisiere Hospitals, APHPParis, FranceLink to full program:bit.ly/3E1bAYQTo access all of our new podcast episodes, subscribe to the CCO Infectious Disease Podcast on Apple Podcasts, Google Podcasts, or Spotify.
In this episode of “Answers From the Lab,” William Morice II, M.D., Ph.D., CEO and president of Mayo Clinic Laboratories, invited Min-Han Tan, M.B.B.S., FRCP, Ph.D., founding CEO and medical director of Lucence, to discuss liquid biopsy cancer testing. Mayo Clinic Laboratories and Lucence recently announced a collaboration to expand access to this cutting-edge cancer test that is designed to detect clinically relevant biomarkers in ctDNA and ctRNA.During their conversation, Dr. Morice and Dr. Tan explore:Inspiration for developing the liquid biopsy.Features that differentiate LiquidHALLMARK® from existing cancer tests.Patients who will benefit from the test and how an oncologist might use the results.The future potential of liquid biopsy advancements.
In this episode, Dr Gideon Hirschfield meets with patient advocate Jess Schnur to discuss challenges related to the diagnosis and management of primary biliary cholangitis (PBC) to provide actionable strategies for healthcare professionals to incorporate into patient care, including:Disease concerns and frequently asked questions from a patient perspectiveManaging symptomsTreatment options and supportive careImportance of awareness and educationPresenters:Gideon Hirschfield, MA, MB BChir, FRCP, PhDLily and Terry Horner Chair in Autoimmune Liver Disease ResearchProfessor, Division of Gastroenterology and HepatologyUniversity of TorontoDirector, The Autoimmune and Rare Liver Disease ProgrammeDirector, Francis Family Liver ClinicToronto General Hospital, University Health NetworkOntario, CanadaJess N. Schnur, BSN-RNNational PBC Patient AdvocateAmerican Liver FoundationDonation Support Services CoordinatorLifeline of OhioColumbus, OhioTo learn more, see the program Hear Me: Patient Perspectives on PBC
This content has been developed for healthcare professionals only. Patients who seek health information should consult with their physician or relevant patient advocacy groups.For the full presentation, downloadable Practice Aids, slides, and complete CME/AAPA information, and to apply for credit, please visit us at PeerView.com/QZC865. CME/AAPA credit will be available until March 3, 2026.Individualizing the PBC Care Pathway: From Baseline and Beyond In support of improving patient care, PVI, PeerView Institute for Medical Education, is jointly accredited by the Accreditation Council for Continuing Medical Education (ACCME), the Accreditation Council for Pharmacy Education (ACPE), and the American Nurses Credentialing Center (ANCC), to provide continuing education for the healthcare team.SupportThis activity is supported by an educational grant from Gilead Sciences, Inc.Disclosure information is available at the beginning of the video presentation.
This content has been developed for healthcare professionals only. Patients who seek health information should consult with their physician or relevant patient advocacy groups.For the full presentation, downloadable Practice Aids, slides, and complete CME/AAPA information, and to apply for credit, please visit us at PeerView.com/QZC865. CME/AAPA credit will be available until March 3, 2026.Individualizing the PBC Care Pathway: From Baseline and Beyond In support of improving patient care, PVI, PeerView Institute for Medical Education, is jointly accredited by the Accreditation Council for Continuing Medical Education (ACCME), the Accreditation Council for Pharmacy Education (ACPE), and the American Nurses Credentialing Center (ANCC), to provide continuing education for the healthcare team.SupportThis activity is supported by an educational grant from Gilead Sciences, Inc.Disclosure information is available at the beginning of the video presentation.
This content has been developed for healthcare professionals only. Patients who seek health information should consult with their physician or relevant patient advocacy groups.For the full presentation, downloadable Practice Aids, slides, and complete CME/AAPA information, and to apply for credit, please visit us at PeerView.com/QZC865. CME/AAPA credit will be available until March 3, 2026.Individualizing the PBC Care Pathway: From Baseline and Beyond In support of improving patient care, PVI, PeerView Institute for Medical Education, is jointly accredited by the Accreditation Council for Continuing Medical Education (ACCME), the Accreditation Council for Pharmacy Education (ACPE), and the American Nurses Credentialing Center (ANCC), to provide continuing education for the healthcare team.SupportThis activity is supported by an educational grant from Gilead Sciences, Inc.Disclosure information is available at the beginning of the video presentation.
In this episode, Jim Garrity spotlights a new ruling on a little-known but powerful tool: the use of depositions as affidavits. As Garrity discusses, a deposition does not need to meet the requirements of trial-oriented Fed. R. Civ. P. 32 (which requires a showing that the party against whom the deposition is offered had notice and a chance to examine the deposition) when it is offered in proceedings that allow testimony by affidavit, such as at summary judgment.SHOW NOTESSurety v. Co. v. Dwight A. Herald, et al., Case No. 1:23-cv-00086-GNS-HBB, 2025 WL 627523 (W.D. Ky. Feb. 26, 2025) (deposition/examination under oath of witness taken in underlying state-court personal injury could be used in federal declaratory judgment actions at summary judgment time, as deposition meets form of affidavit)Diamonds Plus, Inc. v. Kolber, et al., 960 F. 2d 765 (8th Cir. 1992) (deposition need not be admissible at trial to be properly considered in opposition to motions for summary judgment; deposition inadmissible at trial because one of the defendants did not receive proper notice and did not attend the deposition was properly used to create issues of fact justifying denial of summary judgment)Hoover v. Switlik Parachute Co., 663 F.2d 964, 966-67 (9th Cir. 1981) (“Rule 56 ... plainly allows consideration of “affidavits” and we find nothing which requires that term to be construed within the limitations of Rule 32(a).”).First Gaston Bank of North Carolina v. City of Hickory, 691 S.E.2d 715 (Ct. App. N.C. 2010) (citing cases rejecting proposition that FRCP 32 limits use of depositions in proceedings where evidence in affidavit form is admissible; pointing out that to the extent a party objects that they didn't have an opportunity to cross-examine a witness whose deposition from some other cases being offered, “the same objection can frequently be made as to affidavits filed in connection with motions for summary judgment”)Tingey v. Radionics, 193 F. App'x 747, 765–66 (10th Cir. 2006) (reversing summary judgment where trial court, relying on FRCP 32, excluded from consideration in opposition to summary judgment a deposition that plaintiff took of physician in separate state proceeding, where defendant was not party to that proceeding and had not been given notice of deposition; depositions can be used as affidavits in proceedings where affidavits are admissible; to illustrate, “[p]arties may file affidavits in support of summary judgment without providing notice or an opportunity to cross-examine the affiant. See Fed.R.Civ.P. 56(c). The “remedy” for this non-confronted affidavit testimony is to file an opposing affidavit, not to complain that one was not present and permitted to cross-examine when the affidavit was signed. For this reason, the Ninth Circuit has permitted a party to introduce deposition testimony for summary judgment purposes against a party who was not present at the deposition, by construing the deposition as an affidavit. Hoover v. Switlik Parachute Co., 663 F.2d 964, 966–67 (9th Cir.1981)”)Nippon Credit Bank, Ltd. v. Matthews, 291 F.3d 738, 751 (11th Cir. 2002) (without analyzing scope and extent of application of FRCP 32, court broadly said that “Depositions are generally admissible provided that the party against whom they are admitted was present, represented, or reasonably noticed, Fed.R.Civ.P. 32(a), and are specifically allowed in consideration of summary judgment. Fed.R.Civ.P. 56(c). A deposition taken in a different proceeding is admissible if the party against whom it is offered was provided with an opportunity to examine the deponent. Fed.R.Evid. 804(b)(1).”)Fed. R. Civ. P. 56(c)(1)(A) (explicitly allowing citation to depositions for or against summary judgment)8 Charles Alan Wright & Arthur R. Miller, Federal Practice and Procedure § 2142 (1970))) (as are at least as good as affidavits and should be usable whenever an affidavit would be permissible, even where the conditions or requirements for use at trial under rule 32 are not met)
This content has been developed for healthcare professionals only. Patients who seek health information should consult with their physician or relevant patient advocacy groups.For the full presentation, downloadable Practice Aids, slides, and complete CME/MOC/AAPA/IPCE information, and to apply for credit, please visit us at PeerView.com/CFZ865. CME/MOC/AAPA/IPCE credit will be available until February 23, 2026.Strengthening the Immunotherapy Paradigm in Advanced SCAC: Established & Emerging Roles of Immune-Based Platforms Across Lines of Therapy In support of improving patient care, this activity has been planned and implemented by PVI, PeerView Institute for Medical Education, and The Anal Cancer Foundation. PVI, PeerView Institute for Medical Education, is jointly accredited by the Accreditation Council for Continuing Medical Education (ACCME), the Accreditation Council for Pharmacy Education (ACPE), and the American Nurses Credentialing Center (ANCC), to provide continuing education for the healthcare team.SupportThis activity is supported by an educational grant from Incyte Corporation.Disclosure information is available at the beginning of the video presentation.
This content has been developed for healthcare professionals only. Patients who seek health information should consult with their physician or relevant patient advocacy groups.For the full presentation, downloadable Practice Aids, slides, and complete CME/MOC/AAPA/IPCE information, and to apply for credit, please visit us at PeerView.com/CFZ865. CME/MOC/AAPA/IPCE credit will be available until February 23, 2026.Strengthening the Immunotherapy Paradigm in Advanced SCAC: Established & Emerging Roles of Immune-Based Platforms Across Lines of Therapy In support of improving patient care, this activity has been planned and implemented by PVI, PeerView Institute for Medical Education, and The Anal Cancer Foundation. PVI, PeerView Institute for Medical Education, is jointly accredited by the Accreditation Council for Continuing Medical Education (ACCME), the Accreditation Council for Pharmacy Education (ACPE), and the American Nurses Credentialing Center (ANCC), to provide continuing education for the healthcare team.SupportThis activity is supported by an educational grant from Incyte Corporation.Disclosure information is available at the beginning of the video presentation.
This content has been developed for healthcare professionals only. Patients who seek health information should consult with their physician or relevant patient advocacy groups.For the full presentation, downloadable Practice Aids, slides, and complete CME/MOC/AAPA/IPCE information, and to apply for credit, please visit us at PeerView.com/CFZ865. CME/MOC/AAPA/IPCE credit will be available until February 23, 2026.Strengthening the Immunotherapy Paradigm in Advanced SCAC: Established & Emerging Roles of Immune-Based Platforms Across Lines of Therapy In support of improving patient care, this activity has been planned and implemented by PVI, PeerView Institute for Medical Education, and The Anal Cancer Foundation. PVI, PeerView Institute for Medical Education, is jointly accredited by the Accreditation Council for Continuing Medical Education (ACCME), the Accreditation Council for Pharmacy Education (ACPE), and the American Nurses Credentialing Center (ANCC), to provide continuing education for the healthcare team.SupportThis activity is supported by an educational grant from Incyte Corporation.Disclosure information is available at the beginning of the video presentation.
This content has been developed for healthcare professionals only. Patients who seek health information should consult with their physician or relevant patient advocacy groups.For the full presentation, downloadable Practice Aids, slides, and complete CME/MOC/AAPA/IPCE information, and to apply for credit, please visit us at PeerView.com/CFZ865. CME/MOC/AAPA/IPCE credit will be available until February 23, 2026.Strengthening the Immunotherapy Paradigm in Advanced SCAC: Established & Emerging Roles of Immune-Based Platforms Across Lines of Therapy In support of improving patient care, this activity has been planned and implemented by PVI, PeerView Institute for Medical Education, and The Anal Cancer Foundation. PVI, PeerView Institute for Medical Education, is jointly accredited by the Accreditation Council for Continuing Medical Education (ACCME), the Accreditation Council for Pharmacy Education (ACPE), and the American Nurses Credentialing Center (ANCC), to provide continuing education for the healthcare team.SupportThis activity is supported by an educational grant from Incyte Corporation.Disclosure information is available at the beginning of the video presentation.
PeerView Family Medicine & General Practice CME/CNE/CPE Video Podcast
This content has been developed for healthcare professionals only. Patients who seek health information should consult with their physician or relevant patient advocacy groups.For the full presentation, downloadable Practice Aids, slides, and complete CME information, and to apply for credit, please visit us at PeerView.com/HKW865. CME credit will be available until January 31, 2026.Finding the Heat in Cold Tumours: Potential for Perioperative Immunotherapy Strategies in Early Breast Cancer In support of improving patient care, PVI, PeerView Institute for Medical Education, is jointly accredited by the Accreditation Council for Continuing Medical Education (ACCME), the Accreditation Council for Pharmacy Education (ACPE), and the American Nurses Credentialing Center (ANCC), to provide continuing education for the healthcare team.SupportThis activity is supported by an educational grant from Merck Sharp & Dohme LLC, a subsidiary of Merck & Co., Inc.Disclosure information is available at the beginning of the video presentation.
This content has been developed for healthcare professionals only. Patients who seek health information should consult with their physician or relevant patient advocacy groups.For the full presentation, downloadable Practice Aids, slides, and complete CME information, and to apply for credit, please visit us at PeerView.com/HKW865. CME credit will be available until January 31, 2026.Finding the Heat in Cold Tumours: Potential for Perioperative Immunotherapy Strategies in Early Breast Cancer In support of improving patient care, PVI, PeerView Institute for Medical Education, is jointly accredited by the Accreditation Council for Continuing Medical Education (ACCME), the Accreditation Council for Pharmacy Education (ACPE), and the American Nurses Credentialing Center (ANCC), to provide continuing education for the healthcare team.SupportThis activity is supported by an educational grant from Merck Sharp & Dohme LLC, a subsidiary of Merck & Co., Inc.Disclosure information is available at the beginning of the video presentation.
This content has been developed for healthcare professionals only. Patients who seek health information should consult with their physician or relevant patient advocacy groups.For the full presentation, downloadable Practice Aids, slides, and complete CME information, and to apply for credit, please visit us at PeerView.com/HKW865. CME credit will be available until January 31, 2026.Finding the Heat in Cold Tumours: Potential for Perioperative Immunotherapy Strategies in Early Breast Cancer In support of improving patient care, PVI, PeerView Institute for Medical Education, is jointly accredited by the Accreditation Council for Continuing Medical Education (ACCME), the Accreditation Council for Pharmacy Education (ACPE), and the American Nurses Credentialing Center (ANCC), to provide continuing education for the healthcare team.SupportThis activity is supported by an educational grant from Merck Sharp & Dohme LLC, a subsidiary of Merck & Co., Inc.Disclosure information is available at the beginning of the video presentation.
This content has been developed for healthcare professionals only. Patients who seek health information should consult with their physician or relevant patient advocacy groups.For the full presentation, downloadable Practice Aids, slides, and complete CME information, and to apply for credit, please visit us at PeerView.com/HKW865. CME credit will be available until January 31, 2026.Finding the Heat in Cold Tumours: Potential for Perioperative Immunotherapy Strategies in Early Breast Cancer In support of improving patient care, PVI, PeerView Institute for Medical Education, is jointly accredited by the Accreditation Council for Continuing Medical Education (ACCME), the Accreditation Council for Pharmacy Education (ACPE), and the American Nurses Credentialing Center (ANCC), to provide continuing education for the healthcare team.SupportThis activity is supported by an educational grant from Merck Sharp & Dohme LLC, a subsidiary of Merck & Co., Inc.Disclosure information is available at the beginning of the video presentation.
In this episode, Jim Garrity talks about a tactic of some examining lawyers that should, but often doesn't, draw objections that their questions are “argumentative.” So, what is an improper, argumentative question or examination? Here, we're not talking about the questioner's tone or demeanor, i.e., arguing in the classic sense of yelling and bickering with the deponent. We're talking about questions where lawyers aren't really asking a question designed to elicit facts but are instead injecting their own commentary or viewpoint, or injecting insults, taunts, wisecracks, or similar language. "Argumentative" objections are objections to the form, and must be timely made or are waived.SHOW NOTESPeople v. Pawar, No. G037097, 2007 WL 477949, at *2 (Cal. Ct. App. Feb. 15, 2007) (“[W]ere they lying” queries are improper if they are merely argumentative. (Chatman, supra, 38 Cal.4th at pp. 381, 384.) In Chatman, the prosecutor asked the defendant how the safe at a store was opened. (Id. at p. 379.) The defendant replied “he could not say; he never touched the safe,” eliciting the prosecutor's query, “ ‘Well, is the safe lying about you?' “ (Ibid.) The Supreme Court held the question of whether an inanimate object was “lying” was argumentative , defining argumentative inquiry as “speech to the jury masquerading as a question” which “does not seek to elicit relevant, competent testimony, or often any testimony at all.” (Id. at p. 384.))Faile v. Zarich, No. HHDX04CV5015994S, 2008 WL 2967045, at *3 (Conn. Super. Ct. July 10, 2008) (Webster's. . . in the closest relevant definition, defines “argumentative” as “consisting of or characterized by argument: containing a process of reasoning: controversial”)Pardee v. State, No. 06-11-00226-CR, 2012 WL 3516485, at *6 (Tex. App. Aug. 16, 2012) (Steven Goode, et al., Texas Practice Series: Courtroom Handbook on Texas Evidence § 611 cmt. 12 (2012); see United States v. Yakobowicz, 427 F.3d 144, 151 (2d Cir.N.Y.2005) (defining argumentative as “summation-like remarks by counsel during the presentation of evidence”); accord Eddlemon v. State, 591 S.W.2d 847, 851 (Tex.Crim.App. [Panel Op.] 1979) (trial court did not abuse discretion in finding the question, “You don't believe your own offense report?” argumentative). In other words, an argumentative objection concerns whether counsel is attempting to “argue” the case, not whether the counsel is “arguing” with the witness”)United States v. Yakobowicz, 427 F.3d 144, 151 (2d Cir. 2005) (“During the presentation of evidence one of the most commonly sustained objections is that a particular question is argumentative, Fed.R.Evid. 611(a) advisory committee's note to Subdivision (a) to 1972 Proposed Rules, and any summation-like remarks by counsel during the presentation of evidence are improper and subject as a routine matter to being stricken, Mauet & Wolfson, supra, at 30”)Pardee v. State, No. 06-11-00226-CR, 2012 WL 3516485, at *6 (Tex. App. Aug. 16, 2012) ("Many common law objections—including the objection of “argumentative”—are incorporated in the Texas Rules of Evidence. The common law argumentative objection is now governed by Tex.R. Evid. 611 which concerns the mode of interrogation and presentation. The argumentative objection is an objection commonly used, but not commonly understood. Pardee argues the objection should have been sustained because the State was “arguing” with the defendant. Argumentative, though, does not concern counsel's demeanor or tone. Professors Wellborn, Goode, and Sharlot explain the argumentative objection as follows: Counsel may not, in the guise of asking a question, make a jury argument or attempt to summarize, draw inferences from, or comment on the evidence. In addition, questions that ask a witness to testify as to his own credibility are improper.")People v. Chatman, 38 Cal. 4th 344, 384, 133 P.3d 534, 563 (2006) The prosecutor's question about whether the safe was “lying” requires a different analysis. The question was argumentative. An argumentative question is a speech to the jury masquerading as a question. The questioner is not seeking to elicit relevant testimony. Often it is apparent that the questioner does not even expect an answer. The question may, indeed, be unanswerable. The prosecutor's question whether “the safe [was] lying” is an example. An inanimate object cannot “lie.” Professor Wigmore has called cross-examination the “greatest legal engine ever invented for the discovery of truth.” (5 Wigmore on Evidence (Chadbourne rev. ed.1974) § 1367, p. 32.) The engine should be allowed to run, but it cannot be allowed to run amok. An argumentative question that essentially talks past the witness, and makes an argument to the jury, is improper because it does not seek to elicit relevant, competent testimony, or often any testimony at all. Defendant had already explained he had no explanation for the safe being open. Asking whether the safe was “lying” could add nothing to this testimony”)People v. Imbach, No. E040190, 2008 WL 510482, at *7–8 (Cal. Ct. App. Feb. 27, 2008) ("The prosecutor asked, “You found that to be inappropriate but not your other son's addiction to child pornography?” When defendant objected that the question was argumentative, the trial court overruled that objection. Defendant asserted the second “argumentative” objection when defendant's mother said she did not know how to answer that question and the prosecutor asked, “Is that because you didn't want to know?” The trial court sustained the defendant's objection to this second question. Both questions are argumentative, because they both are speeches by the prosecutor masquerading as questions. (Chatman, supra, 38 Cal.4th at p. 384.) The trial court should have sustained both objections. However, we cannot say that by asking those two questions the prosecutor engaged in misconduct.")People v. Peoples, 62 Cal. 4th 718, 793–94, 365 P.3d 230, 288 (2016) (“Defendant observes that the prosecutor asked numerous argumentative questions when cross-examining defense witnesses. To list a few examples, the prosecutor asked defense expert Dr. Lisak, “how many hours are you into them for?” He said to defense expert Dr. Buchsbaum, “Let's quit guessing for awhile and look at the facts.” He said to defense expert Dr. Wu, “It's a pain in the butt to get these test scores.” And he asked prosecution expert Dr. Mayberg, “Did you have a heart attack last night when you looked at the raw data?”)People v. Burns, No. D081051, 2024 WL 2144151, at *15–17 (Cal. Ct. App. May 14, 2024), review denied (July 17, 2024) (excessive repetition of a question simply to make a point can cross line into improper argument”; “Burns makes a strong argument that the prosecutor's repetitive questioning regarding the drunk tank incident became argumentative. “An argumentative question is a speech to the jury masquerading as a question. The questioner is not seeking to elicit relevant testimony. Often it is apparent that the questioner does not even expect an answer. The question may, indeed, be unanswerable.” (People v. Chatman (2006) 38 Cal.4th 344, 384.) “An argumentative question that essentially talks past the witness, and makes an argument to the jury, is improper because it does not seek to elicit relevant, competent testimony, or often any testimony at all.” (Ibid.) Instead, it may be aimed at agitating or belittling the witness (People v. Lund (2021) 64 Cal.App.5th 1119, 1148), or designed to engage the witness in an argument (People v. Johnson (2003) 109 Cal.App.4th 1230, 1236)”)People v. Mazen, No. B300193, 2021 WL 164356, at *5 (Cal. Ct. App. Jan. 19, 2021) The court overruled defendant's argumentative objection to the following question: “Would [accidentally placing the car in neutral] been important information to tell [Morales]?” The court did not abuse its discretion when it overruled the objection. The question sought to elicit relevant testimony regarding defendant's theory that Mario was hit by accident (CALCRIM No. 510). (See People v. Chatman (2006) 38 Cal.4th 344, 384 [“[a]n argumentative question is a speech to the jury masquerading as a question” and does not seek to elicit relevant testimony].)”People v. Singh, No. H042511, 2018 WL 1046260, at *28 (Cal. Ct. App. Feb. 26, 2018) (“Each question anticipated an answer and was answerable; none was “a speech to the jury masquerading as a question”)People v. Basler, No. D068047, 2015 WL 9437926, at *23 (Cal. Ct. App. Dec. 23, 2015) ("Fung appears to identify three categories of objectionable questioning during his cross-examination by the prosecutor. The first category involves apparent sarcasm by the prosecutor. For example, after Fung provided additional details about his fight with another inmate while incarcerated, the prosecutor said, “Okay. You left that part out a couple of minutes ago; right?” Referencing the same fight, the prosecutor made light of Fung's claim of self-defense: “Did you have to defend yourself against him, too?” As another example, when Fung was discussing the extent of his injuries following the fight, the prosecutor said, “So, that's about how badly you were hurt? It looked like something you get by falling off a skateboard?” The court sustained objections to each of these questions, and a number of others, as argumentative." Also from Basler: "As we have noted, Fung contends the first two categories of questions were impermissibly argumentative. “An argumentative question is a speech to the jury masquerading as a question. The questioner is not seeking to elicit relevant testimony. Often it is apparent that the questioner does not even want an answer. The question may, indeed, be unanswerable.... An argumentative question that essentially talks past the witness, and makes an argument to the jury, is improper because it does not seek to elicit relevant, competent testimony, or often any testimony at all.” (People v. Chatman (2006)”)People v. Nanez, No. F064574, 2014 WL 1928307, at *14–15 (Cal. Ct. App. May 15, 2014) (citing examples of argumentative examination by prosecutor including (a) the prosecutor's remark “Convenient” when a witness said they did not remember a particular fact, and (b) when prosecutor commented on witnesses testimony by saying “So that's the lie you're going with?”, and (c) when prosecutor asked witness “You wouldn't tell us if you're lying, of course, right?” and when witness said he would, prosecutor replied “There's another lie,” causing court to strike prosecutor's comment from the record)People v. Strebe, No. D057947, 2011 WL 2555653, at *7 (Cal. Ct. App. June 28, 2011) (trial courses sustained objection to question as argumentative where prosecutor asked witness “Do you remember anything about that evening that might be detrimental to your case?” In essence arguing to jury that witness was lying and only selectively remembered favorable facts)People v. Higgins, 119 Cal. Rptr. 3d 856, 873–74 (Ct. App. 2011), as modified (Jan. 21, 2011), as modified on denial of reh'g (Feb. 4, 2011) (guilty verdict reversed in part due to argumentative questions; among other jabs; in case where defendant explained his conduct as motived by depression due to death of his daughter's friend, prosecutor asked, “You'd agree with me that it's pretty pathetic if you're using the memory of a dead 17–year–old kid as an excuse in this trial, wouldn't you? Would you agree with me? Is that the legacy that you want [the dead teen] to have?”; other examples of prosecutor's argumentative questions included “Oh, the door was unlocked,” and “Isn't that convenient that all of a sudden, right after you've committed the crimes, that that's when you come to?”; further held, “The rule is well established that the prosecuting attorney may not interrogate witnesses solely ‘for the purpose of getting before the jury the facts inferred therein, together with the insinuations and suggestions they inevitably contained, rather than for the answers”)People v. Dixon, No. D047342, 2007 WL 2745207, at *10 (Cal. Ct. App. Sept. 21, 2007) Dixon asked Hernandez who had taken the photographs near the time of the injury. Hernandez testified that the audio-visual person at his school had taken photographs of his injury. Dixon then asked, “Is it computer enhancement? Those could be computer enhanced-.” The prosecutor interrupted, “That's argumentative.” The court sustained the prosecutor's objection")United States v. Browne, No. SACR 16-00139-CJC, 2017 WL 1496912, at *6 (C.D. Cal. Apr. 24, 2017) (For each witness, the Court did not end Defense counsel's cross-examination until it became excessively cumulative and argumentative, at which time the Court was well within its authority to restrain the questioning pursuant to Federal Rule of Evidence 611(a).”)Beving v. Union Pac. R.R. Co., No. 3:18-CV-00040, 2020 WL 6051598, at *12 (S.D. Iowa Sept. 8, 2020) (Defendant may object to prejudicial or argumentative references to counsel at trial as permitted by the Federal Rules of Evidence. See Fed. Rs. Evid. 403, 611(a)(3).)FRE 403: Argumentative questions may be viewed as unfairly prejudicial, misleading, or wasting time.FRE 611(a)(3), Witnesses and Presenting Evidence ((a) Control by the Court; Purposes. The court should exercise reasonable control over the mode and order of examining witnesses and presenting evidence so as to: (1) make those procedures effective for determining the truth; (2) avoid wasting time; and (3) protect witnesses from harassment or undue embarrassment.FRCP 30, Depositions, (d) Duration; Sanction; Motion to Terminate or Limit. (3) Motion to Terminate or Limit, (A) Grounds. At any time during a deposition, the deponent or a party may move to terminate or limit it on the ground that it is being conducted in bad faith or in a manner that unreasonably annoys, embarrasses, or oppresses the deponent or party.