Browsed by
Category: Uncategorized

DEPOSITION OF DEFENSE HIRED SURVIELLANCE INVESTIGATOR

DEPOSITION OF DEFENSE HIRED SURVIELLANCE INVESTIGATOR

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…

Read More Read More

DIRECT EXAMINATION OF ECONOMIST

DIRECT EXAMINATION OF ECONOMIST

I am scheduled to start a trial in a week involving a man who was injured while working. Our economist is scheduled to deliver a baby when the trial is going on  so I  needed to perpetuate her testimony. Here is the simple outline I prepared for her perpetuation deposition. We had discussed this before I used it so she knew the areas I wanted her to cover by these questions. This outline assumes the economist can explain fully the…

Read More Read More

COMMUNICATION LESSONS FROM POLITICAL DEBATES

COMMUNICATION LESSONS FROM POLITICAL DEBATES

Everyone and his brother will have a viewpoint on who did the best job during any political debate. However, we, as trial lawyers, should also view them as learning opportunities for lessons about communications. Let me start with a local political debate between candidates for governor. The present Republican Attorney General Rob McKenna is running against a Democratic former member of congress, Jay Inslee. They held one of several debates last night. It should be noted that I am a…

Read More Read More