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Trial Preparation Defense Strategies Depositions

Marshall Dennehey

Strategies for Combatting Reptile Theory in Medical Malpractice Trials

Marshall Dennehey on

The Reptile Theory is a litigation strategy intended to activate jurors’ survival instincts during trial and is designed to induce fear over logic and reason when hearing a case. Rather than focusing on the standard of care...more

IMS Legal Strategies

Quick Tips For Preparing Your Trial Support Budget

IMS Legal Strategies on

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

U.S. Legal Support

Trial Graphics Presentation: Making an Impact

U.S. Legal Support on

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

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

Hendershot Cowart P.C.

Texas Rule 202: The Advantages of Pre-Suit Depositions in Litigation

Hendershot Cowart P.C. on

Rule 202 refers to the pre-suit deposition rule in the Texas Rules of Civil Procedure. This rule allows a person or party involved in a dispute to request deposition – sworn testimony recorded by a court reporter – to...more

Nextpoint, Inc.

Taking Depositions: Preparation Strategies for Attorneys

Nextpoint, Inc. on

TRIAL PREPARATION SERIES / PART TWO OF THREE - Taking depositions is arguably the most useful discovery exercise to gather information and build a strong case. It is the only opportunity, prior to trial itself, where an...more

Holland & Hart - Your Trial Message

Prepare for Multiple Choice Questions in Deposition

Anecdotally, I have seen it in a few recent cases: The deposition witness isn’t asked an open-ended question and isn’t given a “Yes or No” either. Instead, they are given a range of options, like you would see in an attitude...more

Holland & Hart - Your Trial Message

Know the Other Side’s Three Goals for Your Deposition

So, your deposition has been scheduled, and you’re just starting to wrap your head around what is in store for you. Your lawyer has already stressed that you are not in the driver’s seat at this stage: The deposition is the...more

Nextpoint, Inc.

Follow these 5 Guidelines to Conduct Successful Virtual Depositions

Nextpoint, Inc. on

The new normal is here, and it’s time to embrace the reality of remote, virtual, and hybrid depositions in the world of litigation.  “Remote” depositions are nothing new and have actually been around for several years...more

Holland & Hart - Your Trial Message

Apply Two Tests to Any Battle Between Stories

It’s America’s case of the moment: Johnny Depp and Amber Heard, Hollywood’s former power-couple, now exchanging accusations of physical abuse in a Fairfax, Virginia courtroom. The defamation case initially brought by Depp has...more

Holland & Hart - Your Trial Message

Know How Your Testimony to the Jury Will Differ from Your Deposition

A typical witness preparing for a civil trial often has only one good reference point for what their experience will be, and that is their deposition. That’s where they met opposing counsel, got a taste of that attorney’s...more

Holland & Hart - Your Trial Message

Opening: Build Your House First, Then Take Aim at Their House

I have worked with more than one defendant who simply could not resist it: Right out of the gate, in opening statement, they come out swinging against the plaintiff. They’re not being honest, they have their own share of...more

Holland & Hart - Your Trial Message

Witnesses: Don’t Rely on ‘Catcher Signals’

At a recent meeting with a witness to prepare for deposition testimony, and after I told the witness (more than once) to keep their answers short and not to stray beyond the question when answering, the witness asked, “Could...more

Holland & Hart - Your Trial Message

Don’t Practice til You’re Capable, or til You’re Comfortable — Practice til You Can’t Fail

My daughter is a figure skater — the kind of skater who practices six days a week. Each one of the complex jumps that a skater executes involves dozens of fine-motor movements that need to be encoded into the skater’s muscle...more

Reveal

Using Video Deposition Testimony for Opening Statements & Closing Arguments

Reveal on

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

Holland & Hart - Your Trial Message

Witness Testimony: Understand the Confidence/Competence Circle

For someone starting out in a career, or in some other situation where credibility will be required, there is an expression: “Fake it until you make it.” In other words, if you act like you’ve got it, then people are going to...more

Holland & Hart - Your Trial Message

The Plaintiff Is a Reptile, so Turn Your Witness into a Mongoose

Let’s consider the life cycle of the Reptile — not the slithering, cold-blooded animal, but the strategic approach to arguing plaintiffs’ cases advocated by David Ball and Don Keenan. That perspective, trying to win by...more

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