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Episode 130 - Choosing An "Actor" To Read Deposition Testimony in Evidentiary Hearings and Trials
Episode 130
Today, Jim Garrity talks about a powerful technique for increasing the persuasive impact of deposition testimony that must be read to the trier of fa…
2 years, 4 months ago
Episode 129 -Lessons from the Front Lines: Can Multiple Lawyers Representing the Same Party Each Object During a Deposition?
Episode 129
In our never-ending mission to ensure you're never caught off guard, no matter what the tactic, today we address the question whether multiple lawyer…
2 years, 5 months ago
Episode 128 - Convincing a Court that an EUO is Not a Deposition
Episode 128
Why do some courts and lawyers instinctively react to examinations under oath (EUOs), also called sworn statements, as if they're "secret depositions…
2 years, 6 months ago
Episode 127 -Handling Court Reporters Seeking to Videotape Your Remote Depositions For “Backup Purposes”
Episode 127
The federal rules and their state equivalents do not authorize reporters to designate a method of recording. But one national court reporting conglom…
2 years, 6 months ago
Episode 126 - The Increasingly Poor Odds of Forcing Even Parties to Travel for In-Person Depositions
Episode 126
In today's episode, Jim Garrity discusses the ongoing seismic shift in judicial views about remote video depositions, as reflected in a court ruling …
2 years, 7 months ago
Episode 125 - Handling An Opponents' Last-Minute Notice They're Videotaping Your Client's Deposition
In this episode, Jim covers the problem of opposing lawyers who provide little or no notice of their plan to videotape your client's depositions, and…
2 years, 7 months ago
Episode 124 -Can You Issue a 30(b)(6)-Style Trial Subpoena, Addressed Simply to “Corporate Representative with Knowledge On (Listed Topics)"?
Episode 124
Can you issue a trial subpoena under Fed. R. Civ. P. 45 (or its state equivalents) not to a named person, but instead to a 30(b)(6)-style "Corporate …
2 years, 8 months ago
Episode 123 - Lessons from the Front Lines: Free Transcripts Courtesy of Your Opponent? Maybe. Here's How.
Episode 123
In this episode, Jim Garrity steps up to the plate to take a swing at a controversial tactic: using a request for production to demand an opponent tu…
2 years, 8 months ago
Episode 122 - Lessons from the Front Lines: The Overuse of An Underused 30(b)(6) Technique Leads to Severe Sanctions
Episode 122
In this episode, Jim Garrity talks about a new federal appellate decision that affirmed severe sanctions against a party whose lone designated 30(b)(…
2 years, 9 months ago
Episode 121 - A Review of CaseText's New AI-Powered Deposition Prep Software
Episode 121
In this episode, Jim reviews the force-multiplier capabilities of CaseText's new AI-powered software known as Co-Counsel, introduced just 90 days ago…
2 years, 10 months ago