Before you get to the substantive questions, make sure to ask these four important preliminary questions in every deposition you take. Continue reading
Often you can use more than one discovery method to get the same facts or evidence. You can take a pick-and-choose approach to your methodology, or better yet, use a coordinated approach that aims multiple discovery methods at the same evidence. Continue reading
Filed under: Civil Litigation, Discovery, Legal Topics | Tagged: civil discovery, demand for production of documents, depositions, discovery methods, interrogatories, litigation, pretrial discovery | Leave a comment »
Requests for admission are very valuable yet underutilized tools. They’re one of the best techniques to create admissible evidence for summary judgment and trial—make good use of them! Continue reading
Filed under: Civil Litigation, Discovery, Legal Topics, Litigation Strategy, Pretrial Matters | Tagged: attorneys, discovery, litigation, pretrial, requests for admission, undisputed facts | 2 Comments »
An outline is an excellent tool for making sure you don’t overlook any important subjects during a deposition. But don’t let this tool become a trap: Be in the moment and be ready to venture outside of your outline. Continue reading
As an attorney, you have a duty to do an adequate investigation before asserting any claim, but your investigation can’t intrude on others’ privacy rights. Getting public record information is one way to get what you need without a privacy problem. But what if the information isn’t available online or through a visit to a federal agency? Make a Freedom of Information Act request.
When limited resources means you can’t take as many depositions as you’d like, how do you decide which depo(s) to take? Here’s a priority order to help you triage depositions. Continue reading
Many attorneys mistakenly believe that answers to interrogatories and requests for admission are automatically in evidence after they’re lodged with the court. Not so! First, you’ve got to formally introduce them into evidence.
Filed under: Civil Litigation, Discovery, Evidence, Legal Topics, Litigation Strategy, Trial Strategy | Tagged: discovery, discovery responses, evidence, interrogatories, introducing evidence at trial, requests for admission, trial | 2 Comments »