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Category: Discovery

DEPOSITION OF DEFENSE HIRED SURVIELLANCE INVESTIGATOR

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 INVESTIGATOR (“tailing, stakeout, spying, tracking, snooping, secretly watching, sneak, peeping Tom, prying, invading privacy”) INTRODUCTION 1.NAME (only – not address -save for later) WHAT HE DID GENERALLY  IS IT TRUE STARTING IN MARCH OF 2011 YOU BEGAN SECRETLY WATCHING THE…

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INTERROGATORIES ASKING FOR INSURANCE COVERAGE INFORMATION

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 by  the discovery rules move for production of the policies and study the fine print.  Too often we have been  given erroneous answers to the amount of  insurance  coverage. Here are some suggested interrogatories. The following interrogatories are intended to discover…

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Impeachment on revising deposition testimony

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 versa, materially changing key evidentiary issues for which follow questions would have certainly been asked at the deposition had the defendant answered as appears on the correction sheet. Some responded with the recommendation oftaking a second deposition of the witness…

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