3 Questions to Ask Every Expert Witness at Deposition

three questions to ask an expert witness in a depositionAt an expert’s deposition, questions are primarily focused on the expert’s qualifications and opinions. But don’t forget to ask these three questions—you may be very pleased with the responses you get. Continue reading

How to Tell Litigation Clients to Preserve Digital Information

Did you know that California attorneys have a duty to tell their litigation clients that they must maintain and preserve electronically stored information?  Here’s what to say. Continue reading

4 Things to Know About Exchanging Expert Witness Information

handing document with expert witness informationIf a party serves a timely demand to exchange expert witness information under CCP §2034.210(a), the exchange becomes mandatory and failure to participate in the exchange will preclude a party from offering expert testimony in the case. Perry v Bakewell Hawthorne, LLC (2017) 2 C5th 536, 543. The exchange of expert witness information has specific requirements that can trip you up. Review these four points and you’ll know what to do. Continue reading

Can You Depose by Skype?

Can you depose via Skype? Short answer: Yes. But make sure that you follow the rules. 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

How to Handle Improper Coaching at Deposition

One of the common problems at deposition is improper coaching of the deponent by counsel. If you’re the examining attorney, there are three steps you can take to handle this situation. Continue reading

Are Insurance Agreements Discoverable?

The existence of insurance is often key to a lawsuit and one of the first orders of business in discovery. There are statutory provisions allowing for discovery of the existence and contents of insurance agreements—as well as limits on it. Continue reading

Who May Attend a Deposition?

thinkstockphotos-155804580Generally, depositions are a fairly intimate gathering with only the necessary attendees. But what do you do if you’re surprised by an unwelcome person who insists on being present? Continue reading

Duty to Investigate Before Answering Interrogatories

looking_140478824Before you answer interrogatories, you have a duty to investigate. But what does that mean and how far do you have to go? 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