Podcast Episodes
Back to Search
Episode 41 -Developing Deposition Testimony of Adverse Witnesses So You Can Lead Them During Your Case-In-Chief
Episode 41
In this episode, Jim Garrity offers practical tips for developing deposition testimony that will allow you to use leading questions when examining ad…
4 years, 10 months ago
Episode 40 - Lessons from the Front Lines: I Bet He Didn't Think His Speaking Objections Would be Played for THAT Audience.
Episode 40
In this Lessons from the Front Lines installment - our special episodes where Jim Garrity shines the spotlight on a brand-new court decision of inte…
4 years, 11 months ago
Episode 39 -Do You Need 75, 100, or 150 Interrogatories? FRCP 30(b)(6) to the Rescue!
Episode 39
In this episode, Jim Garrity encourages you to think of Fed.R.Civ.P. 30(b)(6) depositions as an ingenious, unlimited source for additional interrogat…
4 years, 11 months ago
Episode 38 - Can More than One Lawyer for A Party Question the Deponent?
Episode 38
in a conversation with other lawyers recently, Jim Garrity was asked whether more than one lawyer for a party can question the witness in a depositi…
4 years, 11 months ago
Episode 37 - Witnesses for Whom Your Examination Might Best Be Left for Trial
Episode 37
In this episode, Jim Garrity, fresh from a five-day jury trial - his first since March 2020, when COVID-19 began shutting down courtrooms everywhere …
4 years, 11 months ago
Episode 36 - Can an Entity Later Use Affidavits to Contradict the Testimony of Its 30(b)(6) Designee?
Episode 36
We've all heard the mantra that the testimony of a corporate or organizational representative under Fed. R. Civ. P. 30(b)(6) or its state analogues i…
5 years ago
Episode 35 - Lessons from the Front Lines: Excellent Remote Deposition Protocols for Your Depositions
Episode 35
Many lawyers are still struggling to find just the right guidelines or protocols for taking or defending remote depositions. The opportunities for de…
5 years ago
Episode 34 - Consider Delaying Production of True Impeachment Evidence Until After the Key Pertinent Witness Has Been Deposed
Episode 34
Courts generally allow you to withhold true impeachment evidence until after the deposition of a witness to whom the evidence pertains. If you're t…
5 years ago
Episode 33 - Using Depositions on Written Questions as an Offensive Weapon to Stop the Harassment of Deponents
Episode 33
Dealing with an adversary, whether it's an attorney or a pro se litigant, who seems hell-bent on harassing deponents? We've all had to deal with it. …
5 years ago
Episode 32 -Lessons from the Front Lines: Agreeing to the "Usual Stipulations" to Hold Objections Until Trial? You Still Have to Make THIS Critical Objection.
Episode 32
Often, lawyers agree to "the usual stipulations" at the start of the deposition. Just as often, it's unclear what those stipulations are, and how the…
5 years ago