This post explains how to use deposition designations to your advantage for a smooth case planning and trial prep process. Testimony from a living, breathing person is always better than recorded testimony in any legal...more
TRIAL PREPARATION SERIES / PART TWO OF THREE - Taking depositions is arguably the most useful discovery exercise to gather information and build a strong case. It is the only opportunity, prior to trial itself, where an...more
Preparing for the Meet and Confer - Proper preparation and documentation during the Rule 26(f) meet and confer process will greatly improve efficiency in the ediscovery phase of your litigation....more
Rule 30(b)(6) of the Federal Rules of Civil Procedure, which concerns the use of a deposition notice or subpoena directed to an organization, was amended in December 2020 to require that parties meet-and-confer prior to...more
This past year has brought lots of change, including an amendment to Rule 30(b)(6) of the Federal Rules of Civil Procedure. Rule 30(b)(6) governs the deposition of an organization (e.g., a corporation or a partnership) and...more
It is the beginning of a new year and I thought it the ideal time to list out those steps that are absolutely critical when an attorney is confronting his/her obligation to produce e-discovery in connection with a litigation....more
California courts are tired of hearing your demurrers, and now the state has done something about it. Code of Civil Procedure Section 430.41, which went into effect on January 1, 2016, now requires a meet-and-confer process...more