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Episode 110 - "Are You Calling Them A Liar?"
Episode 110
In this episode Jim Garrity tackles the propriety of a question often heard in depositions when the deponent has just contradicted the testimony of a…
3 years, 3 months ago
Episode 109 -Upping Your Background & Lighting Game in Videotaped Depositions of Your Clients
Episode 109
In this episode, Jim Garrity continues his advocacy for litigators’ active management of every facet of their depositions, this time focusing on two …
3 years, 4 months ago
Episode 108 - 32 Factors to Argue (For or Against) In Deposition Location Disputes
Episode 108
In this episode, Jim Garrity alerts you to a federal decision where the judge catalogued thirty-two factors that courts should consider in resolving …
3 years, 5 months ago
Episode 107 - Do Your Non-Party Subpoenas List the Remote Location as “Zoom Video?” You May Have a Problem.
Episode 107
If you're like most litigators, you now regularly issue subpoenas that command the deponent to appear “Via Zoom Videoconference,” or something simila…
3 years, 5 months ago
Episode 106 -A Killer Option for Choosing Potent 30(b)(6) Designees
Episode 106
In this episode, Jim Garrity offers up a clever idea for turning your skills in choosing 30(b)(6) designees into a deposition superpower. On the flip…
3 years, 5 months ago
Episode 105 - Dealing with Deponents Who (For Now) Are Asserting a Fifth Amendment, Spousal, or Other Privilege
Episode 105
Today's we cover a fascinating topic: What to do when your party opponents assert a Fifth Amendment or similar privilege in their deposition? Unlike …
3 years, 6 months ago
Episode 104 - What to Do About Incomplete Answers Caused by Interrupting Examiners?
Episode 104
In this episode, Jim Garrity addresses the problem caused by litigators who repeatedly interrupt your deponents’ answers, potentially resulting in a …
3 years, 6 months ago
Episode 103 -Lessons From The Front Lines: What Will 317 “Don’t Knows,” and 196 “Don’t Remembers,” Earn Your Client? (Hint: It Involves Jurors.)
Episode 103
In this episode, Jim Garrity spotlights a 107-page ruling, issued just three days ago, that offers a sharp reminder about the consequences to depone…
3 years, 7 months ago
Episode 102 - Lessons From The Front Lines: When Suspending Or Terminating A Deposition in Progress Due to Misconduct, Don’t Forget to Say This
Episode 102
There's definitely a right and a wrong way to terminate or suspend a deposition in progress on the grounds it is being conducted in bad faith, or in …
3 years, 7 months ago
Episode 101 -When Are Responses & Objections Due to Document Requests Embedded in a Notice of Deposition Duces Tecum? When Is the Actual Production Due?
Episode 101
In this episode, Jim Garrity talks about dealing with document requests included within a Notice of Deposition Duces Tecum, and how to determine (a) …
3 years, 7 months ago