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Discovery Depositions

Esquire Deposition Solutions, LLC

Recent Rulings Highlight Importance of Depositions in Litigation

In civil litigation, depositions are a key pretrial discovery tool used to uncover facts, obtain admissions, gather evidence for motions, and assess witnesses. They prevent “trial by ambush” by revealing crucial information...more

Esquire Deposition Solutions, LLC

Five Strategies to Optimize Exhibits for Remote Depositions

Litigators don’t always have control over the outcome-determinative evidence in their cases. Often, contracts, accident reports, photographic images, and other critical bits of evidence have in most cases already been created...more

Esquire Deposition Solutions, LLC

How Many Depositions Are Enough?

Ten is the presumptive upper limit on the number of depositions that each party may take in civil litigation in the federal courts. This number, provided by Rule 30(a)(2) of the Federal Rules of Civil Procedure, can be...more

Esquire Deposition Solutions, LLC

Modest $120 Award Created Right to Recover Deposition Costs

We’ve written frequently on ways that parties can recover their costs of suit — particularly deposition-related costs — at the conclusion of civil litigation. Costs related to deposition transcripts used at trial, deposition...more

EDRM - Electronic Discovery Reference Model

Takeaways From Felder v. MGM National Harbor

​​​​​​​Felder v. MGM National Harbor, LLC, 2024 WL 3690779(D. Md. Aug. 7, 2024)(Simms, J.), addresses several important issues. First, in Felder, the Court ordered the parties to conduct a “meet and confer” session.  That,...more

Esquire Deposition Solutions, LLC

Deposition in Hand, Party Need Not Testify at Trial

Are personal injury plaintiffs legally required to testify at their trials? Actually, not. Under the right circumstances, deposition testimony can be used in lieu of live trial testimony if the trial court finds that the...more

U.S. Legal Support

Webinar Recap: Navigating the Legal Landscape with Generative AI

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U.S. Legal Support recently hosted a webinar on the power of generative AI in the legal profession. We partnered with Merlin Search Technologies, a pioneer in the use of AI and large language models (LLMs) to optimize legal...more

Planet Depos, LLC

Top Tips for Your Next Deposition in Asia

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As the only global court reporting firm with U.S.-trained, native English-speaking resources living on the ground in Asia, we provide exceptional service at competitive rates, whether your deposition is in-person, remote or...more

DRI

The Damages Paradox: For What It’s Worth

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All lawsuits start with the potential to someday reach the view of a jury. Yet, the jury’s perspective is often forgotten by attorneys preoccupied with discovery, motion practice, the preparation of witnesses, and the hiring...more

Association of Certified E-Discovery...

Tips for Paralegals and Litigation Support Professionals – May 2024

May 5, 2024 – Imports of TextMap Annotations Into OnCue As Deposition Designations - The OnCue trial electronic presentation software makes it easy to import deposition designations added as annotations in TextMap as new...more

Esquire Deposition Solutions, LLC

eBook: 2024 Guide to Conducting Remote Depositions

This guide provides legal professionals with an overview of how to prepare for and conduct remote depositions in a world that is increasingly adopting hybrid and virtual work environments. By using these best practices,...more

Esquire Deposition Solutions, LLC

Skip Your Deposition and Pay the Price?

We’ve written previously about sanctions that trial courts can impose on parties that, for no good reason, fail to appear for a properly noticed deposition. Courts are understandably impatient with parties that throw sand in...more

U.S. Legal Support

Creating an Expert Deposition Summary

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When preparing for trial, depositions play a foundational role, critical to the discovery phase. After the deposition, having a succinct, accurate deposition summary is a strategic component of developing and refining case...more

Esquire Deposition Solutions, LLC

How to Write an Effective Notice of Deposition

It all starts with a notice. In modern civil litigation, the notice of deposition is the principal means for litigators to ensure that the objectives of deposing a witness are met in a timely, cost-effective, and lawful...more

Esquire Deposition Solutions, LLC

When and How to Use Deposition Summaries

The power of a well-written deposition summary is apparent to anyone who has ever successfully prepared for an examination. Busy students don’t have the time to re-read thousands of textbook pages and lecture notes. Nor do...more

Davis Wright Tremaine LLP

Excessive Fees or Incessant Litigation – Time for Legislative and Employer Action on Retirement Plans!

Commonly referred to as "excessive fee" litigation, class actions that allege retirement plan investments charge too much and earn too little have increased over the past two decades. Excessive fee cases are difficult to...more

EDRM - Electronic Discovery Reference Model

An Epilog: 4 Things You Never Wanted to Hear + 8 Lessons & a Dispute Over Revealing Recipients of Litigation Hold Notices, All in...

I have posted five blogs – – with links below – – on In Re: Social Media Adolescent Addiction/Personal Injury Products Liability Litigation, 2024 WL 1786293 (N.D. Cal. Feb. 20, 2024), subsequent opinion, 2024 WL 1808607 (N.D....more

Planet Depos, LLC

Depositions in Europe: Key Factors to Keep in Mind

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Are you considering taking depositions in Europe but you’re unsure where to start? Don’t worry, our international experts are here to assist you from start to finish! We’ve already covered more depositions throughout Europe...more

Vinson & Elkins LLP

Difficult Decisions About Cloned Discovery Can Leave Companies Seeing Double

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Companies in the midst of government investigations and enforcement actions often must contend with follow-on civil litigation stemming from the same issues. Indeed, due to differing standards of proof, companies that are...more

U.S. Legal Support

Lawyer’s Guide: Deposition vs. Trial Testimony

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The testimony given at a deposition vs. testimony during a trial have a lot in common. They’re both sworn under oath, under penalty of perjury, and part of official court records.  There’s a longer list, however, of how they...more

Esquire Deposition Solutions, LLC

How Requests for Admission Can Trigger Right to Recovery of Deposition Costs

A recent blog post here examined the circumstances under which a prevailing party in litigation can obtain reimbursement for deposition-related costs in federal courts. The rules are complicated, constrained by the statutory...more

U.S. Legal Support

Interrogatory vs. Deposition: Discovery Comparison

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The discovery phase is often the most critical component of legal work, leading 95% of civil cases to a settlement negotiation instead of a courtroom trial. Given this, how information is collected from potential witnesses is...more

U.S. Legal Support

AI’s Role in Deposition Preparation & Analysis

U.S. Legal Support on

There’s no denying it—artificial intelligence is changing the legal landscape. Generative AI and the use of machine learning promise to boost efficiency and reduce prep time through multiple phases of litigation.  For...more

Esquire Deposition Solutions, LLC

The Power of Depositions

Dismissal of a lawsuit is a rare sanction for a discovery violation, but it happened recently in a workplace discrimination lawsuit, due in large part to two probing depositions that called into question one party’s assertion...more

Kohrman Jackson & Krantz LLP

As Seen On TV: Myths and Facts About Litigation

TV shows about lawyers are exciting, fast-paced and sexy. Not so much in real life. While entertaining, attorney TV shows do not reflect the reality of how litigation is conducted and can have a negative effect on what people...more

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