In Pain Center of SE Indiana, LLC v. Origin Healthcare Solutions, LLC, No. 13-cv-133-RLY-DKL, 2015 WL 3631692 (S.D. Ind. June 10, 2015), defendant objected to plaintiffs deposing defendant’s former general counsel, Vandenberg, who submitted a declaration that he did not provide business or financial advice to defendant’s personnel and staff. Defendant argued that the Shelton doctrine precluded the deposition. The court overruled the objection and allowed the deposition to proceed. The court found that there was some basis in the record to support plaintiffs’ assertion that Vandenberg had provided non-legal advice to defendant. The court held inapplicable the Shelton doctrine, which provides that courts should be reluctant to allow discovery of an opponent’s litigation counsel where the information sought is available through other means. The court found that no Seventh Circuit decision has discussed or adopted the Shelton doctrine, and that the district courts in the Seventh Circuit are split on the issue. The court stated it found the line of decisions rejecting the doctrine as more persuasive, and held that plaintiffs could depose Vandenberg, and defendant would need to invoke any privileges or immunities to specific questions. The court cautioned, however, that it would be vigilant in utilizing available sanctions if it became apparent that Vandenberg had so little relevant, non-privileged information that the deposition was a waste of everyone’s time.