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…
With regard to settlement negotiation I like to have a basic form letter to my client where I outline information about the matter. By having it a form I eliminate the problem of overlooking something I should say and it gives me an opportunity to add or revise for the particular case. I’m giving you an example of a letter to the client about this. In addition, I want written settlement authority from my client for any settlement we made….
I recently read a book by Dr. Mardy Grothe,I never metaphor I didn’t Like. It has excellent discussions about metaphor and language which we trial lawyers would benefit from reading. Here are some examples of ones I liked: You were born an original, so don’t die a copy.” Elisabeth Kubler-Ross: People are like stained glass windows. The sparkle and shine when the sun is out, but when the darkness sets in, their true beauty is revealed only if there is…