Alert Your Client to These Depo Issues

When preparing your client for his or her deposition, devote particular attention to explaining the following objectionable areas of inquiry and substantive law on those areas. Continue reading

The Do’s and Don’ts of Building Your Case with Social Media Info

The following is a guest blog post by Renee Galente Stackhouse. Renee is the founder and trial lawyer at Stackhouse, APC, where she focuses on plaintiff’s personal injury and military defense in San Diego. She is the immediate past President of California Women Lawyers, President of the CWL Foundation, Chair of the CLA SSF Section, and sits on the Board of the San Diego County Bar Association.

You would be surprised how easy it is to find public information on the Internet. Or maybe you wouldn’t, given the many stories of jobs lost and cases jeopardized by social media posts. Using Google and social media searches on parties and witnesses can be very helpful to your case, but make sure you don’t overstep. Continue reading

What to Do a Month Before Trial

You’re 30 days from your trial date. Maybe it’s been a while since you’ve gotten this close, or maybe it’s your first time. Don’t worry—here’s a handy chart setting out what you need to do. Continue reading

5 Areas to Cover When Deposing a Party

When taking the deposition of a party, make sure to cover these five areas. Continue reading

5 Rules for Drafting Allegations in a Complaint

Complaints must include a statement of facts constituting a cause (or causes) of action. CCP §§425.10(a)(1), 430.10(e). For those new to litigation, you may be tempted to just get a complaint from a colleague and replace the allegations with your case’s facts. This can be risky if you don’t know the rules that apply to drafting allegations. Continue reading

5 Steps to Handling Nonresponsive Deposition Answers

Whether intentional or not, you may not get an answer to your question in a deposition. How you handle a nonresponsive answer should usually follow this five-step process. Continue reading

Checklist for Disputes Over a Neighbor’s Home Business

home businesses may cause disputes with neighborsA home may be a person’s castle, but it can’t always be his or her office. More home-based businesses (including short-term rentals and home food production) means more neighbor disputes. Here’s a look at what constitutes a home business and a checklist to review whenever you’re asked to consider a dispute involving one. Continue reading

The Benefit of an Effective Medical Expert: More Money

get bigger verdict when using effective medical expert witnessThere’s a definite correlation between the size of personal injury verdicts and the effectiveness of testimony by medical experts. Well-prepared and well-presented medical testimony carries weight and convinces triers of fact. The recent $289 million verdict against Monsanto may be an example. Continue reading

Don’t Miss a Crucial Follow-Up Question

You prepare deposition or investigation questions in advance, but it’s the follow-up questions—often crafted on the fly—that may be the most important. Indeed, Michael Cohen’s lawyer Lanny Davis said that members of the Senate Intelligence Committee failed to ask the right “follow-up questions” when Cohen appeared before them last year and therefore failed to elicit crucial answers. Don’t make that mistake! Continue reading

What to Tell Clients When Discovery Starts

starting discovery responsesOnce discovery starts, you’ll need to contact your client to help with responses. Here’s a sample letter to explain what is happening and what you need from your client. Continue reading