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

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

5 Areas for Questioning an Expert at Deposition

Regardless of an expert’s particular specialty, there are five areas that apply to the questioning of most expert witnesses at deposition. Continue reading

4 Tips for Handling Exhibits at Deposition

463413901When it comes to deposition exhibits, you need to keep your eye on the trial: Make sure they are marked, identified, and attached to the deposition transcript. Here are four tips for handling depo exhibits.  Continue reading

Incoming! 5 Ways to Prepare for Discovery Requests

Your discovery plan shouldn’t be all about what you’re requesting from the other side—it should also anticipate and prepare for the discovery you expect to receive.  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

Timing Your Interrogatories

170189536Interrogatories can be a very powerful discovery tool. With interrogatories, you get to ask questions of adverse parties and then use their answers against them at trial. Don’t miss out on this opportunity by bungling the timing of your interrogatories. Continue reading

4 Preliminary Questions for Every Deposition You Take

185496686Before you get to the substantive questions, make sure to ask these four important preliminary questions in every deposition you take. Continue reading

Which Summary Judgment Document Do You Draft First?

452028697When it comes to preparing a summary judgment motion, many attorneys prepare the supporting documents in the same order each time (and instruct new attorneys to do so, too). But one order may not fit all cases.

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Are Two (or More) Experts Better Than One?

sb10063567v-001Should you hire multiple experts on the same topic? There are some very good reasons to use this strategy. Continue reading