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Trial Preparation Discovery Depositions

EDRM - Electronic Discovery Reference Model

[Webinar] A Winning Story: How to Use Technology to Build and Present a Compelling Case - April 29th, 12:00 pm - 1:00 pm CT

Behind every winning argument is a compelling story. But crafting that narrative is not as simple as piecing together a few pieces of evidence. Legal teams have to prepare for and take depositions, manage transcripts, conduct...more

Marshall Dennehey

Strategies for Combatting Reptile Theory in Medical Malpractice Trials

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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

U.S. Legal Support

Security Best Practices for Remote Depositions in the Digital Age

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Trial outcomes often hinge on witness testimony. Attorneys collect much of this testimony during a formal process called a deposition. A critical component of discovery, depositions traditionally occur in law offices or...more

Law School Toolbox

Bar Exam Toolbox Podcast Episode 305: Spotlight on Civil Procedure (Part 2 – Discovery)

Law School Toolbox on

Welcome back to the Bar Exam Toolbox podcast! This is the second of three episodes in which we review the substantive Civil Procedure law we've covered in our "Listen and Learn" series.  This time we're talking about...more

U.S. Legal Support

Preparing an Effective Notice of Deposition

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Noticing a deposition is a critical part of the litigation process. Far from just a formality, it’s an assurance that a deposition you’re engaging in is being done fairly and in good faith. By giving all interested parties...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

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

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

Courts Sort Through Deposition Format Spats

The post-pandemic litigation environment has seen a rising desire to conduct depositions remotely and a diminishing opposition to remote proceedings. Where litigators do insist on in-person proceedings, those cases are...more

Esquire Deposition Solutions, LLC

Taking Depositions in Mexico

Depositions of witnesses residing in Mexico, at one time a relatively rare occurrence, are becoming commonplace for large law firm litigators. This is because many U.S.-based businesses have relocated manufacturing operations...more

Butler Snow LLP

A Sort of Homecoming: Preparing and Defending the Sales Representative Who Is No Longer with the Company

Butler Snow LLP on

A high school reunion can be a wonderful, surreal experience at best, and a handwringing, anxiety-ridden event at worst. During those formative years of our teenage lives, we were surrounded by – and spent countless hours...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

Five Strategies to Optimize Exhibits for Remote Depositions

Litigators don’t always have control over the outcome-determinative evidence in their cases. Often, contracts, accident reports, photographic images, and other critical bits of evidence have in most cases already been created...more

Esquire Deposition Solutions, LLC

How Many Depositions Are Enough?

Ten is the presumptive upper limit on the number of depositions that each party may take in civil litigation in the federal courts. This number, provided by Rule 30(a)(2) of the Federal Rules of Civil Procedure, can be...more

Association of Certified E-Discovery...

Tips for Paralegals and Litigation Support Professionals – May 2024

May 5, 2024 – Imports of TextMap Annotations Into OnCue As Deposition Designations - The OnCue trial electronic presentation software makes it easy to import deposition designations added as annotations in TextMap as new...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

Skip Your Deposition and Pay the Price?

We’ve written previously about sanctions that trial courts can impose on parties that, for no good reason, fail to appear for a properly noticed deposition. Courts are understandably impatient with parties that throw sand in...more

U.S. Legal Support

Creating an Expert Deposition Summary

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When preparing for trial, depositions play a foundational role, critical to the discovery phase. After the deposition, having a succinct, accurate deposition summary is a strategic component of developing and refining case...more

Esquire Deposition Solutions, LLC

How to Write an Effective Notice of Deposition

It all starts with a notice. In modern civil litigation, the notice of deposition is the principal means for litigators to ensure that the objectives of deposing a witness are met in a timely, cost-effective, and lawful...more

Esquire Deposition Solutions, LLC

When and How to Use Deposition Summaries

The power of a well-written deposition summary is apparent to anyone who has ever successfully prepared for an examination. Busy students don’t have the time to re-read thousands of textbook pages and lecture notes. Nor do...more

U.S. Legal Support

Lawyer’s Guide: Deposition vs. Trial Testimony

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The testimony given at a deposition vs. testimony during a trial have a lot in common. They’re both sworn under oath, under penalty of perjury, and part of official court records.  There’s a longer list, however, of how they...more

Esquire Deposition Solutions, LLC

How Requests for Admission Can Trigger Right to Recovery of Deposition Costs

A recent blog post here examined the circumstances under which a prevailing party in litigation can obtain reimbursement for deposition-related costs in federal courts. The rules are complicated, constrained by the statutory...more

U.S. Legal Support

AI’s Role in Deposition Preparation & Analysis

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There’s no denying it—artificial intelligence is changing the legal landscape. Generative AI and the use of machine learning promise to boost efficiency and reduce prep time through multiple phases of litigation.  For...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

Esquire Deposition Solutions, LLC

Taxation of Deposition-Related Costs in Federal Courts

As litigators know, the United States follows the so-called “American Rule” when apportioning the costs of litigation. Unless a statute specifically provides otherwise, parties in court are responsible for their own...more

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