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

How to avoid common mistakes

From Issue: 2022 June

The Moradi deposition and the underinsured defendant; the treating doctor

From Issue: 2022 May

Who they are, what they do and how to deal with them in a bad-faith case

Create a deposition template for each type of professional you will likely depose and let it be your guide as you explore the expert’s case file

From Issue: 2022 May

Dealing with difficult and dissocial deponents

Experience dictates the kinder approach usually wins with most deponents

Make it harder for defense to justify withholding documents you need

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

Prepare thoroughly so you can shine the light where it belongs, on the issues, and not where they are trying to guide you

Take advantage of the plaintiff’s deposition to showcase the humanity of your client – so the defense sees it, too