Don’t Be Trapped by Your Deposition Outline

463344231An 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

Getting What You Need Under FOIA

78771864As 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.
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Eeny, Meeny…Who Should I Depose?

186468191When 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

Give Discovery Responses a Formal Introduction

136727429Many 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.

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10 Tools for a Successful Depo Examination

177779585We all develop our own deposition style, but there are certain basic tools that every lawyer should have in his or her repertoire. Here are 10 examination techniques to consider adding to your tool belt before your next deposition. Continue reading

Put a “Legal Hold” on Data Destruction

144952362Your client may have the responsibility to preserve electronic evidence, but how to you make sure everyone who has your client’s data gets that message? Send a “legal hold” or data preservation letter to all potential custodians of your client’s relevant data. Continue reading

How to Get the Depo Testimony You Need for Summary Judgment

158557319It’s easy to fall into the trap of not nailing things down in deposition as well as you thought you did. Check out one expert’s advice for getting the deposition testimony you’ll need for your summary judgment motion. Continue reading

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