Techniques Top Attorneys Use When Questioning an Expert

attorney going up a level in her deposition questioningWhen taking an expert’s deposition, you start with questions to learn everything that he or she thinks about the case and has done or plans to do in connection with it. Once that’s done, consider taking your questioning up a level with these three techniques. Continue reading

How to Get Clients Involved in Discovery

lawyer making hand gesture inviting client's participation in discovery decisionsBefore you start discovery, you need to have a plan. Your client should be an integral part of that plan. Here are four ways to get your client involved in discovery decisions. Continue reading

What You Can’t Ask a Juror During Voir Dire

potential jurors waiting to be questioned by the attorneys and the judgeWhen selecting a jury for a civil trial, counsel has pretty wide latitude in terms of the scope of voir dire questions. But there are limits. Continue reading

Begin and End with Your Strongest Questions

use strong question to open and close your cross-examination of a trial witnessWhen cross-examining a witness, almost always begin and end with your strongest questions. Except in a couple of situations. Continue reading

Get a Crash Course from Your Expert

Learn fast from your expert about the area of expertiseSome lawyers decide at the beginning of a case that they’ll never be able to understand what the expert is talking about, and they make no effort to do so. Bad plan! Regardless of the expert’s skill, it’s the lawyer’s responsibility to make sure that his or her expertise is presented to the trier of fact in an admissible and persuasive way. To do that, the lawyer needs to understand the expert’s testimony and field of expertise. Here are four ways to educate yourself fast. Continue reading

12 Grounds for Objecting to Interrogatories

Interrogatories play a key role in litigation: They’re used to gather potential evidence to support a party’s contentions, including facts, witnesses, and writings, or to determine what contentions an opposing party is planning to make. CCP §2030.010(b). But just because they ask doesn’t mean you have to answer. You can object to interrogatories on many grounds. Here’s a list of objections to keep handy when the next batch of interrogatories arrives. Continue reading

How Far Does a Landowner’s Liability Go?

Couple crossing a street from shopping to the parking lotLandowners’ duty to maintain their premises in a reasonably safe condition has a pretty far reach, but the California Supreme Court recently curbed it. Continue reading

Should You Object to Compound Questions?

A question to a witness is objectionable on the ground that it’s compound if it joins two or more questions with the disjunctive “or” or the conjunctive “and.” But it may not always make sense to object. Here’s a look at the dangers of compound questions and how to handle them. Continue reading

5 Steps to Preparing a Deposition Notice

typing out deposition notice on laptopOnce you’ve considered the advantages and disadvantages and have decided to take an oral deposition, you need to draft a written deposition notice. To make sure that you include all the required content, follow these five steps. Continue reading

5 Things to Know Before You Handle an Administrative Action

Many attorneys are unfamiliar with the forum when they find themselves involved in an administrative action. Don’t worry—these tips will help. Continue reading