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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

U.S. Legal Support

Best Practices for Preparing an Expert Witness for Deposition

U.S. Legal Support on

As a trial attorney, you’ll often enlist expert witnesses to evaluate claims, clarify complex evidence, write an expert witness report, and offer authoritative opinions. Because time and money can be tight during trial prep,...more

Stange Law Firm, PC

What is hearsay in divorce and family law matters?

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Hearsay is an important legal concept that lawyers learn in law school. Under Federal Rule of Evidence 801, hearsay is an out-of-court statement offered for the truth of the matter asserted. Even many lawyers are often...more

IMS Legal Strategies

5 Tips for Med Mal Expert Testimony from a Hot Seat Veteran

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As a presentation technology consultant, I have been sitting in the hot seat for almost 25 years. I average one trial a month with about 75% being medical malpractice (med mal) cases. I work with both plaintiff and defense...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

IMS Legal Strategies

Should Your Gen Z Attorney Be Your Hot Seat Operator?

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Gen Z attorneys are often extremely valuable, hard-working additions to your trial team. We are sure many of our clients would agree, as we worked alongside quite a few truly impressive young trial attorneys....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

Orrick, Herrington & Sutcliffe LLP

Depositions in Switzerland: How to Depose a Witness in Switzerland for Litigation in the United States

U.S. lawyers seeking to depose a witness residing in Switzerland for purposes of litigation in the U.S. often seek advice on how to properly do so as a matter of Swiss law and in accordance with the Hague Convention on the...more

IMS Legal Strategies

Quick Tips For Preparing Your Trial Support Budget

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Various “up in the air” factors can potentially boost costs during trial, but most clients will still ask counsel to forecast their budgets. While this request is reasonable, it is not always easy to fulfill....more

Goldberg Segalla

Court Denies Motions for Summary Judgment for Valve and Pump Manufacturers

Goldberg Segalla on

Jurisdiction: Supreme Court of New York, New York County - Plaintiff Robert L. Toth worked at various Consolidated Edison powerhouses from 1961 to 1991 as a sheet metal worker. He was diagnosed with lung cancer in 2019 and he...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

U.S. Legal Support

Realtime Depositions: Enhancing Legal Proceedings

U.S. Legal Support on

Nearly 150 years after Miles Bartholomew introduced the first shorthand machine, the various technologies and tools utilized to record court proceedings and legal matters continue evolving. Today, realtime deposition...more

Esquire Deposition Solutions, LLC

Sidestepping Conflicts and Other Ethical Pitfalls in Employee Depositions

This blog post is the fourth in a series on common ethical challenges that arise when preparing for and conducting depositions. Quite often corporate employers want outside counsel to represent both the corporation and...more

Planet Depos, LLC

Top Tips for Your Next Deposition in Asia

Planet Depos, LLC on

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

Marshall Dennehey

Reporting an Injury via a Petition for Benefits Within 30 Days of the Alleged Accident Does Not Fulfill the Notice Requirement

Marshall Dennehey on

Robert Jorden Bressler v. Florida School Board Assn and Hartford Underwriters Ins. Co., No. 1D2022-4145, Apr. 11, 2024 - The claimant, a senior claims adjuster, worked remotely in Orlando and once a quarter went to...more

Esquire Deposition Solutions, LLC

Can Insurers Dictate How the Insured’s Deposition Will be Conducted?

This blog post is the third in a series on common ethical challenges that arise while preparing for and conducting depositions. Insurers and large corporate legal departments are sophisticated consumers of legal services, but...more

Holland & Knight LLP

Podcast - Impeaching with a Deposition

Holland & Knight LLP on

In this episode of "The Trial Lawyer's Handbook" podcast series, litigation attorney Dan Small discusses what to do when impeaching with a deposition. Impeachment with a prior inconsistent statement is difficult if the...more

Tyson & Mendes LLP

Ten Easily Correctable Mistakes Made in Depositions

Tyson & Mendes LLP on

Depositions are easy if you remember their purpose. A deposition is a record the attorneys are making. Clarity and thoroughness are paramount. In this article, we’ll discuss ten common mistakes attorneys might be making in...more

Esquire Deposition Solutions, LLC

False Testimony During Deposition Calls for Careful Response

This blog post is the second in a series on common ethical challenges that arise when preparing for and conducting depositions. What is a litigator ethically bound to do when a client lies during a deposition? This is not an...more

Esquire Deposition Solutions, LLC

Lawyer “Friend Requests” Are Off-Limits for Deposition Witness Research

This blog post is the first in a series on common ethical challenges that arise when preparing for and conducting depositions. Social media offers such a wealth of details about a person’s circumstances and beliefs that...more

U.S. Legal Support

Trial Graphics Presentation: Making an Impact

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Just what is it that wins a trial case? It’s not a simple matter of providing a bullet list of facts. The subject matter and fine points of evidence can be complex and difficult to follow, and the trial attorneys rarely have...more

Harris Beach PLLC

Extensive Rule Changes to Joint Local Civil Rules in S.D.N.Y. and E.D.N.Y

Harris Beach PLLC on

Effective July 1, 2024, the United States District Court for the Southern and Eastern Districts of New York will impose a series of changes to their joint local rules. These changes mark the culmination “of a multi-year...more

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