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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

Law School Toolbox

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

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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

Esquire Deposition Solutions, LLC

Let’s Not Forget Those In-Person Deposition “Glitches”

Promotional material for a continuing legal education program on deposition practice that crossed our desk recently gave a “pros and cons” assessment of remote versus in-person depositions. And while the authors took care to...more

IR Global

How to Cross-Examine a Witness: A Comprehensive Guide

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Cross-examination is the stuff of drama in fictional courtroom depictions. The savvy lawyer taking on a hostile witness on the stand—these are the moments TV and movie audiences live for. However, the truth is real-life...more

Esquire Deposition Solutions, LLC

Trust, Tech Savvy, Preparation: Keys to New Litigator Success

We have been writing about the personal traits and professional skills litigators need to be successful in pretrial discovery practice for a long time. Whether it’s offering tips on how to master remote depositions, pointing...more

U.S. Legal Support

Preventing Deposition Misconduct

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Given how critical depositions are to the legal process, it stands to reason that fair deposition practices are paramount to a legal team’s success. However, several forms of unethical and unfair conduct can emerge during...more

Fishman Haygood LLP

Testing 1-2-3: Using Focus Groups, Mock Trials, and Shadow Juries in Your Trial Strategy

Fishman Haygood LLP on

Jury testing is a powerful tool in litigation, and attorneys would be well served to think about their cases as studies worthy of experimentation. Cases are not mysteries to be solved; they are a series of testable questions...more

Offit Kurman

Preparing for Deposition Success

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On this episode of Litigator's Lounge, Niall McMillan and Anders Sleight discuss crucial tips for answering questions during depositions. Anders shares valuable advice, highlighting the importance of truthfulness, careful...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

How Not to Defend a Deposition

A fair reading of the facts set out in Phillips Auctioneers LLC v Grosso, 2024 NY Slip Op 33906 (N.Y. Sup. Ct., N.Y. Cty., Oct. 31, 2024), a contract dispute, suggests that both the witness and his attorney were determined to...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

U.S. Legal Support

Fact Witness vs. Expert Witness: Key Preparation Tactics

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As it pertains to building a solid case, persuading jurors, and securing the best chances of a favorable outcome, witnesses can make or break your trial. It’s essential to utilize key witnesses to their full potential during...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

Esquire Deposition Solutions, LLC

Remote Deposition Convenience Doesn’t Defeat Forum Shopping Objections

The convenience and widespread use of remote depositions and virtual hearings will not, in seems, make it any easier for plaintiffs to choose what they believe is the most advantageous forum for litigating their cases....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

U.S. Legal Support

Best Practices for Preparing an Expert Witness for Deposition

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As a trial attorney, you’ll often enlist expert witnesses to evaluate claims, clarify complex evidence, write an expert witness report, and offer authoritative opinions. Because time and money can be tight during trial prep,...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

IMS Legal Strategies

Quick Tips For Preparing Your Trial Support Budget

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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

Holland & Knight LLP

Podcast - Impeaching with a Deposition

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In this episode of "The Trial Lawyer's Handbook" podcast series, litigation attorney Dan Small discusses what to do when impeaching with a deposition. Impeachment with a prior inconsistent statement is difficult if the...more

Tyson & Mendes LLP

Ten Easily Correctable Mistakes Made in Depositions

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Depositions are easy if you remember their purpose. A deposition is a record the attorneys are making. Clarity and thoroughness are paramount. In this article, we’ll discuss ten common mistakes attorneys might be making in...more

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