Develop a Routine: Stock Questions to Ask in Every Deposition

185496686Every case is different, but there are some questions you should ask in most every deposition. Know your routine questions and use them. Continue reading

How Can Someone Be Deposed Twice in the Same Case?

ThinkstockPhotos-501707257Generally, you can’t compel someone to attend a deposition if he or she has been previously deposed in the same case. But there are 5 exceptions to this rule. Continue reading

Size Up Your Adversary

ThinkstockPhotos-494299501When it comes to litigating a case, your client’s objectives are only half the story. If you want to gain an advantage, you’ll also need to successfully assess your adversary’s goals, capabilities, and willingness to fight. Continue reading

6 Things to Know About Interrogatory Responses

ThinkstockPhotos-158217439So, you’ve been hit with interrogatories. Before you start working on responses, review these 6 points. Continue reading

4 Questions to Ask Before Moving for a Discovery Protective Order

153000711In California, civil discovery is “self-executing,” i.e., a party demanding discovery doesn’t need prior court approval, and the responding party may object instead of providing the requested information. An objection often ends the matter, but sometimes it doesn’t, and the party resisting discovery has to consider moving for a protective order. Continue reading

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

%d bloggers like this: