Yes, we typically then point out that much of what they want is
available on line, and frequently negotiate with opposing counsel to
moderate demands for depositions, etc., but, in the end, we propose,
the judge and opposing counsel dispose. That won't change.
I'd want to set the depo rate high enough that if someone has to be
deposed, he or she will at least feel that the money makes up for
the hassle.
For people with unique skills or knowledge, $800/hr is not unusual.
So long as the rate is published ahead of time, you're not going to
get much argument. ("Yes, we know it's high. But we've already told
you how to download stuff yourself for free.")
R's,
John