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Amendments to CR 26 and 30 Will Change Discovery and Deposition Practice

WA Bar News

They will require a material change in the way many attorneys practice discovery. 1, 2024, codify procedure for depositions by remote means. Except for special proceedings, a case schedule deadline to disclose experts does not excuse a party from timely responding to expert discovery to the extent responsive information is available.

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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. First , where the plaintiff designated her therapist as an expert witness on emotional distress damages, her disclosure of privileged attorney-client communications in otherwise privileged therapy sessions waived the privileges. Austin , 2024 WL 4056761 (D. 5, 2024)(Coulson, J.),

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What “Expenses” Can a Non-Party Recover for Complying With a Discovery Subpoena?

E-Discovery LLC

45 (“Subpoena”) states: (b)(1) – Under some circumstances, witness fees and mileage must be paid. [1] They produced documents and a privilege log, but objected to a deposition. OLPC moved to compel a deposition and for additional documents or an updated privilege log. Kuendig’s deposition. Fed.R.Civ.P.

Subpoenas 130
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Deposition Misconduct: Rules, Risks, and Remedies

WA Bar News

Fucile “[T]estimony of witnesses who were kicked by plaintiff’s attorney while the witnesses were responding to defendants’ attorney’s inquiry. because there is no way of knowing what the testimony would have been if the witnesses had been left alone.” — West v. should not be considered as evidence. Irwin (E.D.

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Deposition Prep Like a Pro: Insights from a Paralegals Playbook

Speaker: Kaitlyn "The Persnickety Paralegal" Story

Deposition preparation is a critical aspect of a paralegal's role, requiring meticulous attention to detail and proactive management of the case timeline. This includes knowing the rules, being on top your deadlines, and being able to find that sweet spot between receiving discovery responses and expert designations.

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DEPOSITION OUTLINE OF A MEDICAL MALPRACTRICE DEFENSE EXPERT

Plaintiff Trial Lawyer Tips

There are a volume of available ideas and outlines for the discovery deposition of a medical malpractice expert including advice to not take the deposition at all in some circumstances. WITNESS EVER NAMED IN LAWSUIT AS DEFENDANT OR PLAINTIFF? PAST EXPERIENCE AS EXPERT WITNESS 1. A. INTRODUCTION 1.

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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.