Podcast Episodes

Episode 142 - Deposition Protocol Stipulations

Episode 143

In this episode, Jim Garrity discusses deposition protocol stipulations, which are agreements between the parties that establish the framework for noticing and conducting depositions. They're common…

Published on 1 year, 2 months ago

Episode 141 - Depo Case Digest for the Week of July 5, 2024

Episode 141

Our depo case digest episodes present a fast roundup of new deposition-related rulings nationwide. Today: (1) Two new rulings on relevance as a basis to instruct a witness not to answer a question, o…

Published on 1 year, 2 months ago

Episode 140 -Depo Case Digest: (1) OK to Make Pre-Depo Demand for 30(b)(6) Designee Names (2) Courts Favoring In-Person Depos Again (3) Checking Court Reporter Bills for Fleas and Ticks

Episode 140

As a result of listener requests, today we add a new kind of show—the Depo Digest episode—to our podcast. These new segments will supplement the regular single-topic deep dives for which we're known.…

Published on 1 year, 3 months ago

Episode 139 - Unpeeling the Layers of the Deponent's Memory

Episode 139

According to current cognitive psychology and neuroscience understanding, our memories are multilayered constructs composed of personal experiences and information acquired from external sources. So,…

Published on 1 year, 3 months ago

Episode 138 - When Must a Party Produce Documents to Be Used By a 30(b)(6) Designee at Deposition (Or Reviewed Beforehand?)

Episode 138

In this episode, Jim tackles the problem of 30(b)(6) witnesses showing up with voluminous notes and documents to use in refreshing their memory about the topics to be addressed. Are these witnesses …

Published on 1 year, 4 months ago

Episode 137 - Deploying Multiple Lawyers to the Same Deposition? Follow These Tips to Secure Fee Awards for All

Episode 137

Do you sometimes send multiple lawyers to depositions? If so, it's important to know how to maximize your odds of taxing each lawyer's fees when you prevail in the action and file your fee petition. …

Published on 1 year, 4 months ago

Episode 136 - Every Word Matters. See Them with Zoom's Live-Caption Feature.

Episode 136

Jim Garrity's observation is that many litigators are still not using Zoom’s live-caption feature in depositions. This setting is perfect for clients and other participants who want to watch remote d…

Published on 1 year, 5 months ago

Episode 135 - Lessons from the Front Lines: Don’t Forget Evidentiary Support When Seeking Protective Orders to Relieve Deponents of Travel for Depositions

The court ruling in the spotlight today is a reminder that it's critically important to include evidentiary support when you seek a protective order - to relieve a party or witness of the obligation …

Published on 1 year, 5 months ago

Episode 134 - Deposition Interpreters Redux: Correcting Inaccurate Interpretations

Episode 134

In this episode we answer a listener who wanted to know how to correct a deposition transcript where the errors were caused by the interpreter, not by the court reporter. It's an important episode, b…

Published on 1 year, 5 months ago

Episode 133 - Who Pays the Initial Cost of a Deposition Interpreter?

Episode 133

Charges for deposition interpreters can easily double the cost of the deposition itself. So, who pays, and what's the underlying principle? What if the deponent speaks English but still demands an in…

Published on 1 year, 5 months ago