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Episode 31 - Clearing Out the Testimonial Cobwebs at the Start of Your Depositions
Episode 31
What's the best way to prevent evasive witnesses, as you wrap up their depositions, from claiming they didn't understand many of your questions, and/…
5 years, 1 month ago
Episode 30 - How to Sharply Reduce the Cost of Deposition Transcripts
Episode 30
If you're like Jim Garrity, court reporting and transcript costs have become a major factor in your firm's or organization's operations. Smaller firm…
5 years, 1 month ago
Episode 29 - Lessons from the Front Lines: Are You Entitled to Depose a Witness Previously Deposed by Another Party?
Episode 29
In this Lessons from the Front Lines episode, based on a February 1, 2021 federal court ruling, Jim Garrity takes Episode 28 a step further. Previous…
5 years, 1 month ago
Episode 28 - Preventing (Or Obtaining) A Second Deposition of A Party or Witness
Episode 28
Your opponent sends you an email saying he just needs an "update deposition" of your client. What say you? In this episode, Jim Garrity notes that an…
5 years, 2 months ago
Episode 27 - Is It Okay to Confer with Clients About Their Testimony During Deposition Breaks?
Episode 27
Have you ever had a lawyer challenge you about conferring with your client during breaks in depositions, or suggest that you're violating some rule o…
5 years, 2 months ago
Episode 26 - Lessons from the Front Lines: Regret Terminating a Deposition? UN-terminate It Immediately.
Episode 26
In today's Lessons from the Front Lines - special episodes where we spotlight new deposition-related rulings in active lawsuits around the U.S. - Ji…
5 years, 2 months ago
Episode 25 - Can You Be Sued for Questions You Ask in Depositions?
Episode 25
In this episode, Jim Garrity talks about the risk litigators face of being sued for asking deposition questions that deponents perceive as defamatory…
5 years, 2 months ago
Episode 24 - The Stunning Consequences of Setting "Short-Notice" Depositions
Episode 24
Join Jim Garrity in a deep dive into the law of short-notice depositions, which can trigger astonishingly severe consequences. The federal rules defi…
5 years, 3 months ago
Episode 23 - Cross-Notice Jiu Jitsu: Using An Opponent's Cross-Notice Against It
Episode 23
It's not unusual for adversaries to cross-notice your key depositions, either of their own witnesses or of non-party deponents. That allows them unf…
5 years, 3 months ago
Episode 22 - FRCP 29(a) Stipulations: A Way to Save Time, Money & Headaches
Episode 22
In this episode, Jim Garrity talks about one of the greatest time and money-saving tools you've never heard of. Fed. R. Civ. P. 29(a) stipulations al…
5 years, 3 months ago