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Depositions Litigation Strategies

Esquire Deposition Solutions, LLC

Failure to Schedule Depositions Together Was Discovery Abuse

Recent amendments to the federal rules governing pretrial discovery encourage courts to be more aggressive in squelching wasteful discovery practices. Litigators should be mindful that judges are increasingly taking the rules...more

EDRM - Electronic Discovery Reference Model

[Webinar] A Winning Story: How to Use Technology to Build and Present a Compelling Case - April 29th, 12:00 pm - 1:00 pm CT

Behind every winning argument is a compelling story. But crafting that narrative is not as simple as piecing together a few pieces of evidence. Legal teams have to prepare for and take depositions, manage transcripts, conduct...more

Esquire Deposition Solutions, LLC

Massachusetts Remote Deposition Rule Takes Effect

New court rules went into effect in Massachusetts last month that authorize remote depositions whenever the party noticing the deposition elects that format. A prior proposal to make in-person depositions the default option...more

Marshall Dennehey

Strategies for Combatting Reptile Theory in Medical Malpractice Trials

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The Reptile Theory is a litigation strategy intended to activate jurors’ survival instincts during trial and is designed to induce fear over logic and reason when hearing a case. Rather than focusing on the standard of care...more

Esquire Deposition Solutions, LLC

What to Do After Asserting a Deposition Objection

The rule seems simple enough: Attorneys defending a witness during a deposition may instruct the witness not to answer questions only for the purpose of protecting privileged information. And yet, if the number of trial court...more

Law School Toolbox

Bar Exam Toolbox Podcast Episode 305: Spotlight on Civil Procedure (Part 2 – Discovery)

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Welcome back to the Bar Exam Toolbox podcast! This is the second of three episodes in which we review the substantive Civil Procedure law we've covered in our "Listen and Learn" series.  This time we're talking about...more

Esquire Deposition Solutions, LLC

Let’s Not Forget Those In-Person Deposition “Glitches”

Promotional material for a continuing legal education program on deposition practice that crossed our desk recently gave a “pros and cons” assessment of remote versus in-person depositions. And while the authors took care to...more

IR Global

How to Cross-Examine a Witness: A Comprehensive Guide

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Cross-examination is the stuff of drama in fictional courtroom depictions. The savvy lawyer taking on a hostile witness on the stand—these are the moments TV and movie audiences live for. However, the truth is real-life...more

Esquire Deposition Solutions, LLC

Trust, Tech Savvy, Preparation: Keys to New Litigator Success

We have been writing about the personal traits and professional skills litigators need to be successful in pretrial discovery practice for a long time. Whether it’s offering tips on how to master remote depositions, pointing...more

Esquire Deposition Solutions, LLC

Free Speech Case Tests Texas Rule on Pre-Suit Depositions

Everything is bigger in Texas. Even pretrial discovery rules, which permit depositions to be taken merely for the purpose of investigating whether a lawsuit should be filed. No state is more permissive when it comes to...more

Esquire Deposition Solutions, LLC

The Apex Doctrine and Remote Depositions

The apex deposition doctrine is a judge-made rule that protects company executives from harassing, repetitive depositions in cases in which the executive has little relevant evidence to provide. Courts applying the doctrine...more

U.S. Legal Support

Witness Coaching vs. Preparation

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The line between ethical witness preparation and unethical coaching is somewhere between ensuring a witness doesn’t show up unprepared for a legal proceeding and putting words in their mouth. Incorporating a solid trial...more

U.S. Legal Support

Preventing Deposition Misconduct

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Given how critical depositions are to the legal process, it stands to reason that fair deposition practices are paramount to a legal team’s success. However, several forms of unethical and unfair conduct can emerge during...more

U.S. Legal Support

Deposition Interpreters: What to Expect

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Depositions provide the opportunity for legal teams to evaluate not just words, but truthfulness, demeanor, and believability. However, language barriers between deponents and attorneys can hinder the pursuit of information,...more

Esquire Deposition Solutions, LLC

New Minnesota Rule Removes Roadblocks to Remote Depositions

Revised Minnesota pretrial discovery rules, which took effect Jan. 1, now encourage remote depositions by allowing them to be set by notice alone. Former practice required either a court order or stipulation....more

Fishman Haygood LLP

Testing 1-2-3: Using Focus Groups, Mock Trials, and Shadow Juries in Your Trial Strategy

Fishman Haygood LLP on

Jury testing is a powerful tool in litigation, and attorneys would be well served to think about their cases as studies worthy of experimentation. Cases are not mysteries to be solved; they are a series of testable questions...more

Offit Kurman

Preparing for Deposition Success

Offit Kurman on

On this episode of Litigator's Lounge, Niall McMillan and Anders Sleight discuss crucial tips for answering questions during depositions. Anders shares valuable advice, highlighting the importance of truthfulness, careful...more

Marshall Dennehey

Pennsylvania Court Issued Discovery Sanction Against Defendants for Late Production of Evidence, Opening Door to Questioning...

Marshall Dennehey on

Brown v. Brooks, 2024 WL 5008506, No. 23-2966 (E.D. Pa. Dec. 6, 2024) - This matter involved a motor vehicle accident between the plaintiff and a laundry truck driver, and it illustrates the danger of errors during discovery....more

U.S. Legal Support

Preparing an Effective Notice of Deposition

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Noticing a deposition is a critical part of the litigation process. Far from just a formality, it’s an assurance that a deposition you’re engaging in is being done fairly and in good faith. By giving all interested parties...more

Esquire Deposition Solutions, LLC

Citing Wildfire Threat, Court Says Attorney Need Not Travel for In-Person Deposition

The devastating wildfires that raced through southern California these past few weeks caused loss of life, property damage in the billions of dollars, and upheaval in the lives of millions of Americans who live in that...more

Esquire Deposition Solutions, LLC

Sanctioning Deposition No-Shows in 2025

The blog post Turning Deposition No-Shows to the Client’s Advantage proved popular with our readers when written (2021!) and for years afterward. The sustained readership of that article is gratifying but also disappointing...more

Array

Top 5 Deposition Trends Reshaping the Litigation Landscape in 2025

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The deposition market, a crucial component of the litigation support industry, is evolving rapidly. Technology advancements, shifting client expectations, and changes in the legal landscape are reshaping how depositions are...more

Esquire Deposition Solutions, LLC

Account for Everyone Involved in Remote Depositions

Last week’s blog recounted the story of a litigator surprised by the unannounced, off-camera presence of the witness’s mother in the room during her son’s remote deposition. That should never have happened and, in modern...more

Foley & Lardner LLP

Litigation Avoidance, Part I: Balancing the Time and Expense of Discovery to Achieve Better Outcomes

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We understand. The other party to your contract breached your deal, acted in bad faith, and cost you money and your business reputation. It’s personal; you trusted them, and they abused your trust. You want to sue them...more

Zelle  LLP

Minnesota’s Amended Rule 30.02 Embraces the Era of Remote Depositions

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Minnesota Rule of Civil Procedure 30.02 has been amended to expressly authorize parties to conduct depositions via remote technology and require a party seeking to take a deposition to elect between deposing in-person or...more

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