Plaintiff Trial Lawyer Tips

                               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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The coronavirus situation has had a dramatic impact on the processing of damage cases. Requirements for social distancing and, in some states, requirements to shelter at home have brought the judicial process to a halt. In many jurisdictions’ trials have been stopped and courthouses virtually closed. However, there is a need for ongoing discovery procedures to preserve evidence in anticipation of when trials will resume. One possible solution involves remote teleconferencing meetings and teleconferencing depositions. Technology allows one to connect…

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In cases where the client may not survive to trial it may be necessary to perpetuate their testimony. How this is handled depends almost entirely on the circumstances involving the client and the general style  or approach of the lawyer. Having some limited experience with perpetuation depositions of dying clients in cases like  mesothelioma cases and like cases I have some ideas. The video setting is very important. The first issue is the camera position and what is being filmed….

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