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Discovery Best Practices Depositions

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

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

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

Esquire Deposition Solutions, LLC

When Mere Objections Are Not Enough

It’s a common practice during a deposition for lawyers to assert legal objections to witness testimony but then allow the deposition to proceed. In fact, this practice is broadly encouraged. Depositions are wide-ranging...more

Esquire Deposition Solutions, LLC

What to Include in a Deposition Letter

The receipt of a notice for a client’s deposition usually sets off a chain reaction of familiar events in most law offices across the country. The deposition is calendared. Materials requested in the notice or accompanying...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

How to Navigate Common Remote Deposition Trouble Spots

Even today some attorneys approach remote depositions with a small measure of trepidation. They worry that the lack of physical proximity diminishes their ability to engage with the deponent. They wonder how they can...more

Esquire Deposition Solutions, LLC

Turning Deposition No-Shows to the Client’s Advantage

This post is addressed to the attorney who has properly noticed the deposition of an opposing party for but, for some reason, the intended deponent has failed to appear at the appointed time and place. A basketball metaphor...more

TransPerfect Legal

Best Practices for Remote Depositions – Be Prepared!

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When the US began to shelter in place, the wheels of litigation came to a grinding halt and decades-old practices suddenly were in question. Remote depositions used to go forward in places like Tahiti. Now, a remote...more

Esquire Deposition Solutions, LLC

Four Best Practices for Remote Depositions

According to a recent Thomson Reuters report on trends and benchmarking, one of the highest priorities for firms and legal departments in 2018 was controlling litigation costs. Many organizations see remote depositions as a...more

Esquire Deposition Solutions, LLC

Common Mistakes in 30(b)(6) Witness Preparation

Under Federal Rule of Civil Procedure Rule 30(b)(6), a party may depose a public or private corporation, a partnership, an association, a governmental agency, or another entity. Of course, it is not actually possible to...more

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