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Episode 21 - Wizards and Codes: How to Precisely Track The Elapsed Examination Time During A Deposition
Episode 21
Did you know your court reporter's machine keeps track of the total elapsed time of the examination while the deposition is in progress? Right down t…
5 years, 3 months ago
Episode 20 - Apex Depositions
Episode 20
You need to depose a high-ranking government or corporate official, but their lawyer refuses, saying the official is protected by the Morgan Doctrine…
5 years, 3 months ago
Episode 19 - Lessons from the Front Lines: 922 Deposition Objections. (Then Sanctions Happened.)
Episode 19
In a November 30, 2020 Memorandum Order, a federal judge imposed sanctions against a lawyer for alleged excessive and improper objections during depo…
5 years, 4 months ago
Episode 18 - The New Change to FRCP 30(b)(6), Effective December 1, 2020
Federal Rule of Civil Procedure 30(b)(6) - the subsection that allows you to compel an organization to produce a representative who can testify know…
5 years, 4 months ago
Episode 17 - Can You Ask the Same Questions In Depositions That You Just Asked (And Got Answers To) In Interrogatories?
Courts have been ruling on the question for years: Is it proper to ask the same questions in depositions that you just asked (and received answers to…
5 years, 4 months ago
Episode 16 - Contesting Excessive Expert Deposition Fees
Episode 16
What to do when you reach out to schedule an opponent's expert witnesses for deposition, and are told that you've got to pay the experts an outrageou…
5 years, 4 months ago
Episode 15 - Remote Deposition Protocols for COVID and Beyond
Episode 15
Tired of fighting over protocols for your remote depositions? We've got the solution. In this episode, Jim Garrity discusses a fourteen-page list of …
5 years, 4 months ago
Episode 14 - Lessons from the Front Lines: Asked and Answered Objections
Episode 14
A November 10, 2020 Discovery Order from a California federal judge says "asked and answered" objections are improper speaking objections. Jim Garrit…
5 years, 4 months ago
Episode 13 - The Real Reason to Cross-Notice A Deposition
Episode 13
Should you cross-notice depositions set by another lawyer? How does cross-noticing benefit you? What's the chief reason you ought to cross-notice a…
5 years, 4 months ago
Episode 12 - What's the Right Way to Make Form Objections?
Episode 12
You're defending a deposition, and the form of the examining lawyer's questions are improper. What's the correct way to make your form objection? Is …
5 years, 5 months ago