Plaintiff Trial Lawyer Tips

OCTOBER 31, 2024

THREE PRIMARY DEFENSE CLAIMS __ __ __ PLAINTIFF PROOF OF CAUSATION __ DEFENDANT CAUSATION DEFENSE _ PRELIMINARY STATUS REVIEW  Review local rules regarding deadlines and requirements DISCOVERY REVIEW Interrogatories  Review defendant’s answers to interrogatories. Note incomplete answers for motion. Supplement if needed.

Cross-Examination 100

Cross-Examination Exhibits Interrogatories Opening Statement 100

Plaintiff Trial Lawyer Tips

OCTOBER 17, 2024

“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.

Depositions 100

Depositions Interrogatories Witnesses Exhibits 100

WA Bar News

NOVEMBER 12, 2024

1, 2024, codify procedure for depositions by remote means. That was always the rule if CR 33 (interrogatories) and CR 34 (requests for production) were read. DEPOSITIONS BY REMOTE MEANS Amendments to CR 30, addressing depositions by remote means, were proposed by the BJA Remote Proceedings Work Group and adopted effective Oct.

Depositions 66

Depositions Discovery Objections Exhibits 66

E-Discovery LLC

AUGUST 13, 2024

The Court “presided over a discovery dispute hearing related to Plaintiff’s motions to compel interrogatory requests and requests for production of documents, and related to a motion for a protective order filed by the Defendant.” Plaintiff later complained of lack of depositions. 7, 2024)(Simms, J.), emphasis added].

Discovery 130

Discovery Depositions Interrogatories Objections 130