5 Tips for Preparing Your Witness for Video Deposition

175649389Preparing your witness for a video deposition has a few more wrinkles—or more accurately, the ironing out of a few more wrinkles—than a deposition recorded only by stenography. Continue reading

Are Requests for Admissions a Magic Bullet or Overblown?

466464237Requests for admission are one of the best techniques to create admissible evidence for summary judgment and trial. Every litigator should understand the advantages of using them but also their limitations. Continue reading

Give the Reporter a Hand to Get a Clean Depo Transcript

117533578When you’re taking a deposition, you know that ensuring a complete and accurate record is vital. So don’t take the person who’s dutifully taking down the proceedings for granted: Assisting the court reporter is not only polite, it might be the key to a clean depo transcript to use at trial. Continue reading

Like Steve Jobs, Unavailable Witnesses Can Still “Appear” at Trial

451334569In the trial of an antitrust case against Apple, Steve Jobs will come back to life as a key witness—if only in the form of his videorecorded deposition. Continue reading

Timing Your Interrogatories

170189536Interrogatories can be a very powerful discovery tool. With interrogatories, you get to ask questions of adverse parties and then use their answers against them at trial. Don’t miss out on this opportunity by bungling the timing of your interrogatories. Continue reading

5 Things to Do Before Deposing an Expert

92419672Taking the deposition of an opponent’s disclosed expert entails more and different preparation than when you’re deposing a lay witness. Here are 5 things to do when prepping for an expert’s deposition. Continue reading

4 Preliminary Questions for Every Deposition You Take

185496686Before you get to the substantive questions, make sure to ask these four important preliminary questions in every deposition you take. Continue reading

%d bloggers like this: