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Category: Discovery

HOW TO PREPARE YOUR CLIENT FOR THEIR DEPOSITION by Lita Luvera

HOW TO PREPARE YOUR CLIENT FOR THEIR DEPOSITION by Lita Luvera

“By failing to prepare, you are preparing to fail” Benjamin Franklin In our office, my law partner and wife, Lita Barnett Luvera, legal responsibilities included preparing clients and witness for their deposition. The other lawyers relied upon her for the preparation and she was very good at it. Lita had a procedure which she followed and has outlined for full explanation. Here is the procedure she followed in her words. INTRODUCTION Your goal is to become your client’s new best…

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MEMO RE DISCOVERY ABOUT SURVEILLANCE

MEMO RE DISCOVERY ABOUT SURVEILLANCE

                               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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FIVE BASIC CONSIDERATIONS REGARDING TELECONFERENCING DEPOSITIONS

FIVE BASIC CONSIDERATIONS REGARDING TELECONFERENCING DEPOSITIONS

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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