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A SIMPLE ATTORNEY DEPOSITION PREPRATION CHECKLIST

A SIMPLE ATTORNEY DEPOSITION PREPRATION CHECKLIST

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We all know how to take depositions, but sometimes  we forget the basics  because we think we don’t have to prepare. Here’s a very simple outline of things to consider before you take a deposition.  It’s a reminder of what we should consider before we depose someone. PRELIMINARY PREPARATION  1. MAKE COPIES  OF THE CIVIL RULE: The Civil Rules relating to deposition discovery have provisions governing conduct and objections that are permissible during a deposition. With some defense counsel it may…

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DEPOSITION OF DEFENSE HIRED SURVIELLANCE INVESTIGATOR

DEPOSITION OF DEFENSE HIRED SURVIELLANCE INVESTIGATOR

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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

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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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