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Episode 71 - Lessons from the Front Lines: A Plaintiff Escapes Sanctions for Using Public Records Requests to Gather Information During a Discovery Stay
Episode 71
In this episode - one in a recurring series where we share brand new deposition-related court rulings from around the country - Jim Garrity tells you…
4 years, 5 months ago
Episode 70 -Can Non-Record Lawyers Participate in the Depositions of their Non-Party Clients?
Episode 70
In this episode, Jim Garrity brings clarity to a quandary experienced by many litigators: Can the non-record lawyers of non-party deponents show up…
4 years, 5 months ago
Episode 69 - So, What About Standing (a/k/a Continuing or Running) Objections?
Episode 69
In this episode, Jim Garrity discusses so-called standing objections, where - in theory - the parties agree that defending lawyers need not make cont…
4 years, 5 months ago
Episode 68 -Objecting to the Use of Partial or Incomplete Documents in Depositions
Episode 68
Why do litigators feel comfortable dismembering emails, and showing deponents only fragments of the actual conversation? More importantly, why do the…
4 years, 5 months ago
Episode 67 - Do Deposition Subpoenas Expire?
Episode 67
In this episode, Jim Garrity addresses the question whether your deposition subpoena, which contains a specific date and time for appearance, in fact…
4 years, 6 months ago
Episode 66 - Something to Know About Our Show Notes: We're Constantly Adding to Them
Episode 66
Did you know? Our show notes - where we list the cases and other authorities on which each episode is based - are dynamic. That means we're constant…
4 years, 6 months ago
Episode 65 -Who's Zoomin' Who? Identifying Your Remote Deponents' Off-Screen Cheat Sheets
Episode 65
What exactly have your remote video deponents placed in front of them - on their screen, on the floor, on sticky notes, on a second monitor and elsew…
4 years, 6 months ago
Episode 64 - Proving "Unavailability" in Order to Use Depositions at Trial
Trial is approaching, and you learn a witness you planned to call live now isn’t available. You'll need to read or play their deposition testimony in…
4 years, 6 months ago
Episode 63 -About That Pesky Notice Language (For Use in Discovery "And/Or At Trial")
Episode 63
In this episode, Jim Garrity explores the effect of language added by many litigators in their notices that the deposition may be used (apart from di…
4 years, 6 months ago
Episode 62 -A Tool for Motivating Deponents to Reveal What They Know, Without Fearing Retaliation
Episode 62
In this episode, Jim Garrity shares a valuable tool for protecting the identities of nonparty deponents and, in the process, protecting their careers…
4 years, 6 months ago