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Category: Direct Exam

DIRECT EXAMINATION OUTLINE FOR YOUR OWN CLIENT

DIRECT EXAMINATION OUTLINE FOR YOUR OWN CLIENT

I have just returned from Hawaii where I took a deposition of my client because he has a fatal lung cancer and I wanted to perpetuate something of him by way of  video deposition. Here is the basic outline I prepared, however the client has a tracheotomy and is unable to speak.  He also has a serious hearing  problem, both the result of over radiation for a head tumor. He is in bed at home and the only way to…

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