Category Archives: Discovery

A SIMPLE ATTORNEY DEPOSITION PREPRATION CHECKLIST

We all know how to take depositions, but sometimes  we forget the basics  because we think we don’t have to prepare. Here’s a very simple outline of things to consider before you take a deposition.  It’s a reminder of what we … Continue reading

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DEPOSITION OF DEFENSE HIRED SURVIELLANCE INVESTIGATOR

I recently deposed an investigator hired by the defense who kept my client under surveillance over a long period of time. While you may not have had this happen to your client you may find the outline helpful. EXAMINATION OF … Continue reading

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INTERROGATORIES ASKING FOR INSURANCE COVERAGE INFORMATION

Does your state discovery rules allow you to  ask  the defendant about insurance coverage? If so, you should always take advantage of that right. Insist upon complete answers and don’t be  satisfied with answers like “adequate insurance exists.” If allowed … Continue reading

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