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Discovery From Former Attorney About Disputed Quid Pro Quo Offer to Opponent

E-Discovery LLC

11, 2024), involved a request for discovery from a former Town attorney concerning an offer that he allegedly made to plaintiffs. The court: set out the governing standard for discovery from an attorney and, denied a request to depose the attorney; but, authorized a limited interrogatory to him. Albra , 2024 WL 4471672 (S.D.N.Y.

Discovery 130
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Discovery of Surveillance Video is Permitted Only After Deposition of Plaintiff

E-Discovery LLC

Plaintiff also presented a fall-back privilege log issue: “Plaintiff argues that if Defendant is permitted to withhold the video until after his deposition, he should be required to include more detail on his privilege log, including exact dates of surveillance and descriptions of the video(s)’ contents.”

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Felder Part 2 of 4:  Defendant Sanctioned for Late Cancellation of Depositions

E-Discovery LLC

defendant was sanctioned for belatedly canceling depositions that were scheduled at the discovery cutoff date. In this employment discrimination case, the defendant had noted depositions of Ms. Jones’ deposition. We notified you as soon as we learned the depositions would not be going forward.” 7, 2024)(Simms, J.),

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Self-Collection, Discovery About Discovery, and Curative Sanctions

E-Discovery LLC

Among them were: general principles of discovery; the role of counsel in self-collection; discovery on discovery; the date that the litigation hold was triggered; whether reasonable post-trigger steps were taken; curative sanctions under Fed.R.Civ.P. It insists that it is not conducting unchecked discovery.”

Discovery 130
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Privilege Waiver by: Disclosure to Therapist; and, in Rule 30(b)(6) Deposition Preparation

E-Discovery LLC

the Court addressed two important discovery issues. Second , where a Rule 30(b)(6) deponent reviewed an allegedly privileged document in deposition preparation in order to refresh her memory, the privilege, if any, was waived. In Faulkenberry v. Austin , 2024 WL 4056761 (D. 5, 2024)(Coulson, J.), at *2 (emphasis added).

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HOW TO PREPARE YOUR CLIENT FOR THEIR DEPOSITION by Lita Luvera

Plaintiff Trial Lawyer Tips

“By failing to prepare, you are preparing to fail” Benjamin Franklin In our office, my law partner and wife, Lita Barnett Luvera, legal responsibilities included preparing clients and witness for their deposition. Too often, lawyers tend to schedule an hour or two in their office on the day of the deposition to prepare their client.

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Deposition Misconduct: Rules, Risks, and Remedies

WA Bar News

In this column, we’ll address a narrower, but more common, subset of deposition misconduct that the ABA opinion touches on: improper “coaching” during depositions and improper objections intended to impede the questioner. 10 Second, we’ll focus on depositions rather than hearings or trials. Washington RPC 4.4(a)