Production Problems: Formatting E-Data

ThinkstockPhotos-164446354Producing electronic data in discovery can be complicated by format issues: How do you determine which format to use? Continue reading

4 Tips for Contention Interrogatories

ThinkstockPhotos-486765445Interrogatories may be the only discovery procedure that can be used to discover a party’s contentions. You can use them to ask an opponent to state whether he or she makes a particular legal contention, to state the factual basis for the contention, and to identify any witnesses or documents supporting the contention. But before you draft your next set of contention interrogatories, review these four tips. Continue reading

Stipulations for the End of a Depo

ThinkstockPhotos-179049810There are certain stipulations entered into at the end of the deposition that can be very useful. Check out these stipulation suggestions, along with sample language to get them on the record. Continue reading

6 Reasons to Use Interrogatories

ThinkstockPhotos-494315642Interrogatories are the discovery workhorse, with at least six major strengths. Consider the following benefits of propounding interrogatories as you plan discovery for your case. Continue reading

Getting Your Client Ready for Deposition

ThinkstockPhotos-460416523For most clients, being questioned in a deposition is a new and frightening experience. The more you can do to prepare your client, the better he or she will feel and perform. When it comes to instructing your client on how to respond to questions in a deposition, use this handy checklist to be sure you don’t miss anything—some of this may seem obvious to you, but probably not to your client. Continue reading

Tips for Dealing with a Difficult Deponent

200397990-001If you take depositions, it’s inevitable that you’ll encounter deponents who are difficult to question. In addition to maintaining a professional manner, consider using one or more of the following strategies, based on the difficulty you’re facing. Continue reading

Questions to Ask When Deposing an Expert

ThinkstockPhotos-142081160The task of deposing the opposition’s expert is simplified immeasurably by keeping in mind the deposition’s fundamental purpose: to discover all of the expert’s opinions and all of the bases for those opinions. Your goal should not be to impeach the expert but rather to concentrate on learning everything the expert thinks about the case, has been told or learned about the case, and has done or plans to do in connection with the case. To help reach that goal, here’s a checklist of questions to consider asking when you’re deposing the opposition’s expert. Continue reading

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