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Litigation Strategies Video Recordings Federal Rules of Civil Procedure

EDRM - Electronic Discovery Reference Model

How Not to Negotiate an ESI Protocol? Say it is “Mandatory”; and, Demand That Discussions be Recorded

In Wilbert v. Pyramid Healthcare, Inc., 2025 WL 873947 (W.D. Pa. Mar. 20, 2025), the court wrote: From the inception of this action, Counsel for the parties could not agree on the scope and methodology for ESI discovery…....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

Esquire Deposition Solutions, LLC

62-Hour Trek to Palau or Remote Deposition From Home? You Be the Judge

Palau is an island archipelago in the Pacific Ocean. The local economy depends on tourism, mainly from visitors interested in snorkeling and scuba diving along its beautiful barrier reefs. Tourism aside, the Palau economy is...more

Burr & Forman

Florida Supreme Court Amends Summary Judgment Procedural Rule to Mirror Federal Doctrine

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Florida courts have required the moving party to “conclusively disprove” the nonmovant’s theory of the case in order to eliminate any issue of fact, whereas the federal doctrine permits the entry of summary judgment when...more

Rumberger | Kirk

New Year, New Florida Summary Judgment Standard

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It’s Time to Adapt Your Litigation Strategy to a More Flexible Summary Judgment Standard - On the final day of 2020, the Florida Supreme Court waived adieu to the past in two related decisions on the summary judgment...more

Rumberger | Kirk

Video Evidence Sets the Stage for Florida's Highest Court to Expand Summary Judgment Opportunities

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One of the most important differences between the Florida and Federal judicial systems is the treatment of summary judgment motions.  The distinction arises from differing judicial attitudes rather than the wording of the...more

Reveal

Using Video Deposition Testimony for Opening Statements & Closing Arguments

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Trial advocacy is a mix of law and theater, requiring a lawyer to know both the law and their audience. Attorneys must effectively argue their client’s case using the evidence and the jury instructions to show their client is...more

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