- PLAINTIFF’S SHOULD ALWAYS START BY ATTACKING THE DEFENDANT
- ADVICE ABOUT BEING A BETTER ADVOCATE
- “TIMID SALESPEOPLE HAVE SKINNY KIDS” – LEARN HOW TO ASK FOR THE VERDICT
- WE FORGIVE MISTAKES BUT PUNISH SINFUL CONDUCT
- CONSIDER A SETTLEMENT CHECKLIST TO AVOID MISTAKES
- ARE YOU A “WHACK A MOLE” TRIAL LAWYER?
- “In the spring of 1971, I met a girl” LESSONS OF GREAT STORY TELLING
- LESSONS FROM ONE OF AMERICA’S GREATEST TRIAL LAWYERS – EARL ROGERS
- TWO BOOKS ABOUT COMMUNICATIONS WITH IDEAS YOU SHOULD CONSIDER
- THE DEVIL MADE ME DO IT OR REFUSING TO TAKE RESPONSIBLITY
- BASIC TORT DEFENSES
- DEALING WITH THE DEFENSE “IT WOULD HAVE HAPPENED NO MATTER WHAT WAS DONE”
- TRIAL LESSONS FROM A RECORD VERDICT OUTCOME
- TWO IMPORTANT CONCEPTS: ANCHORING & THE MIND-BODY CONNECTION
- OUTLINE FOR DIRECT EXAMINATION OF PLAINTIFF HUMAN FACTORS EXPERT
- WHAT DO YOU DO WHEN THE WHEELS BEGIN TO FALL OFF YOUR CASE?
- COMMENCEMENT SPEAKER ADVICE APPLIES TO TRIAL LAWYERS
- HOW DO YOU EVALUATE DAMAGES FOR A CHILD SHOULDER DYSTOCIA CASE?
Category Archives: Discovery
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
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
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