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Month: May 2023

MEMO RE DISCOVERY ABOUT SURVEILLANCE

MEMO RE DISCOVERY ABOUT SURVEILLANCE

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                               I have had the issue of the defense or insurance company hiring someone to spy on my client in the hopes it will show the client is not hurt as badly as claimed. What follows is the raw memo I developed in anticipation of creating a deposition outline. You hopefully may create ideas from it if you have the issue. (FRAME AS: “tailing, stakeout, spying, tracking, snooping, secretly watching, sneak, peeping Tom, prying, invading privacy”) INTRODUCTION . 1.Name,…

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WHAT YOU SHOULD KNOW ABOUT THE IMPACT OF DEATH OF A LOVED ONE

WHAT YOU SHOULD KNOW ABOUT THE IMPACT OF DEATH OF A LOVED ONE

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Trial lawyers represent people who have lost a loved one as a result of some negligent act. While they are familiar with the analysis and preparation of the liability case, the damage case may be a challenge for them. In order to present the damage consequence of a wrongful death case, the lawyer needs to understand what the client is going through. Psychodrama is a helpful way to do this when properly conducted. Here is a brief outline of some…

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