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

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

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

OCTOBER 17, 2024

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. They also sought the former attorney’s deposition regarding the alleged offer. Thus, those two factors weighed in favor of a deposition.

Discovery 130

Discovery Depositions Interrogatories Settlement Negotiations 130

E-Discovery LLC

AUGUST 16, 2024

The court rejected plaintiffs’ request for a query to “ to serve as the jumping off point for a collaborative, potentially iterative conversation with persons with technical knowledge of StubHub’s data, aimed at identifying those tables containing relevant information needed to adequately answer Plaintiffs’ Interrogatories.” emphasis added].

Interrogatories 130

Interrogatories Discovery Depositions Litigation 130

E-Discovery LLC

MAY 31, 2024

Here, the burdens associated with the proposed discovery, including re-doing liability expert reports and depositions, are heavy; and the likely benefits, given the elapsed deadlines, are nil. Failure to Object to Untimely Interrogatories Coupled With a Discovery Violation Leads to Reversal (Jan.

Interrogatories 130

Interrogatories Discovery Counterclaim Objections 130

MyCase

MAY 7, 2024

Reclaim Hours Save up to three hours per discovery document with AI-generated responses to: Requests for production Requests for admission Interrogatories Notice of deposition Third-party subpoenas Form interrogatories 2.

Discovery 52

Discovery Interrogatories Subpoenas Admissibility 52