Depositions

The theatrics of deposing employer representatives

You must rehearse for every deposition as if it was the role of a lifetime, and this requires a script

From Issue: 2023 March

Once you finish the pre-deposition with your client, they should feel protected, empowered, and ready to fight for themselves

From Issue: 2020 April

Tips for preparing and taking depositions in an employment case

From Issue: 2024 April

Make it harder for defense to justify withholding documents you need

Effective use of videotaped depositions at trial

Prepare your client to give a deposition that supports her credibility and your case

From Issue: 2025 March

Dealing with difficult and dissocial deponents

Experience dictates the kinder approach usually wins with most deponents

How to avoid common mistakes

From Issue: 2022 June

The Moradi deposition and the underinsured defendant; the treating doctor

From Issue: 2022 May

Inadequately prepared experts may end up giving testimony that can damage your case

Taking the PMQ deposition and using it effectively at trial

From Issue: 2024 April