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Minerva26

One Court's Novel Approach to Addressing the Gap Between Search Term Hits and Produced Documents

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Effective management of discovery disputes is critical in litigation, particularly as courts enforce stricter adherence to discovery deadlines. A recent decision in Valeo Schalter und Sensoren GmbH v. NVIDIA Corp. highlights...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

Esquire Deposition Solutions, LLC

Beyond Witness Preparation

Thorough preparation of the deposition witness is critical to successful deposition practice. Prior to the deposition, the witness should be advised how and when to respond to questioning, the roles of counsel and the court...more

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

Butler Snow LLP

Practice Pointers and Potential Pitfalls of a Corporate Deposition

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A corporate deposition authorized by Fed. R. Civ. P. 30(b)(6), and similar state rules[1] is a powerful discovery device with far-reaching implications. Entities served with such a notice face significant burdens to select...more

Butler Snow LLP

Subpoenaed Remote Testimony from Anywhere and Everywhere? Ninth Circuit Says No.

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With the COVID pandemic, remote video depositions and trial testimony very quickly went from rare to routine. Remote testimony, for the most part, is viewed as a convenience to both witnesses and attorneys, and parties and...more

Troutman Pepper Locke

EDVA Permits Plaintiff to Use Her Deposition as Trial Testimony

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It is not uncommon in litigation for parties to introduce testimony through depositions taken for use at trial. It is very uncommon, though, for a party to request to use their own deposition testimony as their trial...more

Esquire Deposition Solutions, LLC

The Power of Depositions

Dismissal of a lawsuit is a rare sanction for a discovery violation, but it happened recently in a workplace discrimination lawsuit, due in large part to two probing depositions that called into question one party’s assertion...more

U.S. Legal Support

Exploring Different Types of Depositions

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Though typically conducted in a conference room, a deposition can take place in many locations and through a variety of methods. So long as you capture a verbatim record, either face-to-face or remotely through the use of...more

Husch Blackwell LLP

A Non-Expert with Expertise: Navigating the Risks and Rewards of Testimony from Highly Sophisticated Professional Employees in...

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Corporate defendants are frequently faced with a quandary—is the company’s highly sophisticated professional employee simply a fact witness or does their anticipated testimony propel them into the world of expert discovery?...more

Esquire Deposition Solutions, LLC

The 4 Reasons to Conduct a Deposition

No other pretrial discovery process rivals the deposition for its ability to alter the course of civil litigation. Depositions alone bring litigators face-to-face with key witnesses, experts, and the parties themselves in a...more

Esquire Deposition Solutions, LLC

The Four Types of Depositions

There are four main ways to conduct a pretrial deposition in modern law practice: the deposition by written question, the in-person deposition, the remote deposition, and the hybrid deposition. Each has its strengths and...more

ArentFox Schiff

You Can(not) Say That Again: Using a 30(b)(6) Corporate Witness’s Deposition Testimony at Trial

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Can a corporate party affirmatively use deposition testimony from its own 30(b)(6) witness at trial? It depends. Corporate Witness Testimony at the Deposition Stage - A quick primer on corporate witnesses under Federal...more

Jackson Lewis P.C.

To Be (Discoverable), or Not to Be: Notetaking During an Attorney’s Internal Investigation

Jackson Lewis P.C. on

Introduction- Picture this: you are on-site at a new client’s headquarters for a weeklong hostile work environment investigation into several internal complaints made against the CEO and CFO. This is the first engagement...more

Esquire Deposition Solutions, LLC

Do Remote Depositions From Home Violate Rule 45(c)’s 100-Mile Subpoena Limit?

We recently blogged about a case in which a court ruled that a subpoena for a remote deposition did not violate Federal Rule of Civil Procedure 45(c)’s 100-mile limit on subpoenas for non-party witnesses because the deponent...more

Proskauer - Minding Your Business

Key Takeaways from the Amendment to Rule 30(b)(6)

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

Troutman Pepper Locke

The Nuts And Bolts Of Local Practice In The Eastern District Of Michigan (Part 3): A Guide To Practicing In The U.S. District...

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A civil jury trial is a risky proposition in any court, state or federal. To manage that risk, it is usually in each party’s interest to engage in some form of alternative dispute resolution, or ADR. Knowledge of the local...more

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