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Category: Discovery

INTERROGATORIES ASKING FOR INSURANCE COVERAGE INFORMATION

INTERROGATORIES ASKING FOR INSURANCE COVERAGE INFORMATION

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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Impeachment on revising deposition testimony

Impeachment on revising deposition testimony

I’d like to share an e-mail discussion among some plaintiff lawyers regarding the followingquestion: What do you all do when you get back the deposition corrections sheet from the defendant and find many "yes"s are changed to "no"s and visa versa, materially changing key evidentiary issues for which follow questions would have certainly been asked at the deposition had the defendant answered as appears on the correction sheet. Some responded with the recommendation oftaking a second deposition of the witness…

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Deposition report form

Deposition report form

While we are taking the deposition testimony of a witness wefrequently think of projects that should be done and note issues that are significant. This is in addition to forming an impression of the witness. Too frequently we are so involved in the deposition process we fail to make notes of these matters or, if we do make notes, we file the yellow pad paper and forget it. Later when we want to recall the witness impression or review the…

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