Podcast Episodes
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Episode 81 - How (and Why) to Ask Deponents About Prior Sworn Testimony
Episode 81
In this episode, Jim Garrity stresses the importance of systematically asking deponents to catalogue their prior testimonial experience in any form o…
4 years, 1 month ago
Episode 80 - Taking Depositions Before and After A Lawsuit
In this episode, Jim Garrity does a deep dive into Fed. R. Civ. P. 27 (and its state equivalents, because virtually all U.S. states and territories h…
4 years, 2 months ago
Episode 79: An Email Is Not a Notice of Taking Deposition (But It Could Be)
Episode 79
In this episode, Jim Garrity discusses an October 21, 2021 ruling granting a protective order blocking plaintiffs' depositions set on short notice. …
4 years, 2 months ago
Episode 78: Lessons from the Front Lines: Why Google Couldn't Prevent the Apex Deposition of CEO Sundar Pichai
Episode 78
In this Lessons from the Front Lines episode, Jim Garrity analyzes Google's opposition to the deposition in a class action of its highest-level offic…
4 years, 3 months ago
Episode 77 - Listener Questions About Depositions by Written Questions
Episode 77
In this episode, Jim Garrity answers some listener questions about depositions by written questions, and shares additional thoughts about the techniq…
4 years, 3 months ago
Episode 76 - Demystifying Depositions by Written Questions
Episode 76
In this episode, Jim Garrity explains how depositions by written questions work, and when to use them. Many lawyers have never deposed a witness this…
4 years, 3 months ago
Episode 75 - Lessons From The Front Lines: Never Let Opponents Control the Timing & Sequence of Your Depositions
In this episode, Jim Garrity talks about the sequence and timing of your depositions. Who is allowed to go first? What if the opposing lawyers insi…
4 years, 3 months ago
Episode 74 - Can You Read the Entirety of an Adverse Party’s Depositions at Trial, Even When the Deponents Are Available to Testify Live?
Episode 74
In this episode, Jim Garrity looks at a tactic expressly allowed by the rules, but almost always prohibited by judges, specifically the reading of th…
4 years, 4 months ago
Episode 73 - Lessons from the Front Lines: Lawyer Suspended 91 Days for Allegedly Text-Coaching Remote Deponent
Episode 73
In this episode, Jim discusses the November 18, 2021 decision of the Florida Supreme Court suspending a lawyer who was allegedly caught text-coaching…
4 years, 4 months ago
Episode 72 - Set Your Depositions Unilaterally After Asking for Dates…How Many Times?
Episode 72
In this episode, Jim Garrity tackles a sometimes-sticky question: How many times do you have to ask an opponent or witness for deposition dates bef…
4 years, 4 months ago