Plaintiff Trial Lawyer Tips

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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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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Lawyers USA in its May 7, 2007 issue has an excellent article about a plaintiff trial lawyer Dorothy Clay Sims in Florida and her tactics in dealing with medical experts who claim her plaintiff’s are malingerer’s. I highly recommend reading the article. She has even created a company to help lawyers in this regard called MDinnaBOX.com. They provide medical expert consultation with doctors in New Delhi at reasonable rates. These doctors are available to "listen in" to a deposition through…

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