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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 -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 regu…

1 year, 9 months ago

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

1 year, 10 months ago

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

1 year, 10 months ago

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

1 year, 11 months ago

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

1 year, 11 months ago

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

1 year, 11 months ago

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Episode 134 - Deposition Interpreters Redux: Correcting Inaccurate Interpretations
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 b…

1 year, 11 months ago

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

2 years ago

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Episode 132:  Pre- or Post-Deposition? Deciding When To Seek A Protective Order For Objectionable 30(b)(6) Topics
Episode 132: Pre- or Post-Deposition? Deciding When To Seek A Protective Order For Objectionable 30(b)(6) Topics

Episode 132

In today's episode Jim Garrity answers a question that vexes many litigators relating to corporate representative depositions under Fed. R. Civ. P. 3…

2 years, 2 months ago

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Episode 131 -The Question to Ask after “Did You Take Any Medications That May Affect Your Testimony Today?"
Episode 131 -The Question to Ask after “Did You Take Any Medications That May Affect Your Testimony Today?"

Episode 131

In this episode, Garrity points out an important but usually overlooked followup question to ask right after you ask deponents if they took medicatio…

2 years, 3 months ago

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