Category Archives: Discovery


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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Impeachment on revising deposition testimony

I’d like to share an e-mail discussion among some plaintiff lawyers regarding the followingquestion: What do you all do when you get back the deposition corrections sheet from the defendant and find many "yes"s are changed to "no"s and visa … Continue reading

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Deposition report form

While we are taking the deposition testimony of a witness wefrequently think of projects that should be done and note issues that are significant. This is in addition to forming an impression of the witness. Too frequently we are so … Continue reading

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