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Litigation Strategies American Bar Association (ABA) Depositions

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

Washington Revises Rules for Remote Depositions

The Washington Supreme Court recently approved significant revisions to that state’s procedural rules on remote depositions. Revised Rule 30 of the Washington Civil Rules will now allow remote depositions to be noticed...more

Esquire Deposition Solutions, LLC

Proceed With Caution on Out-of-State Depositions

Many attorneys have long and successful careers without ever having to practice law outside of the jurisdiction where they obtained their license. But for litigators and in-house counsel, the need to be conversant with the...more

Esquire Deposition Solutions, LLC

Quick Tips for Ethical, Effective Deposition Witness Prep

If the word “Shaq” conjures up the image of professional basketball legend and amiable IcyHot liniment pitchman Shaquille O’Neal, you could be missing out on a valuable mnemonic device for preparing witnesses for deposition:...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

Remote Depositions Buoyed by Skilled Litigators and Innovative Technology

When the COVID-19 pandemic struck in 2020, experienced litigators quickly discovered that they would have to adapt and learn to thrive in a new adversarial arena — the computer monitor. And adapt they did....more

Esquire Deposition Solutions, LLC

Massachusetts High Court Considers New Rule on Remote Depositions

Massachusetts appears poised to become the latest jurisdiction to permanently embrace — and regulate — the practice of conducting pretrial discovery with remote depositions. A public comment period recently closed on a...more

Esquire Deposition Solutions, LLC

The New “Usual Stipulations”

According to news accounts, a recent discovery deposition in a Pennsylvania business dispute went off the rails when defending counsel refused to agree to “the usual stipulations.” The attorney’s refusal to agree to “the...more

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