Steno

JANUARY 6, 2025

Executive Summary Challenge: After decades of litigation experience, attorney Mike Marzban recognized that colleagues were often too shy to provide candid feedback on his deposition technique. He needed an objective way to evaluate his performance and identify potential blind spots in his questioning strategies.

Depositions 52

Depositions Objections Discovery Litigation 52

E-Discovery LLC

NOVEMBER 27, 2024

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. That motion was granted in part, with the court ordering the law firm to produce documents or an adequate privilege log and compelling the deposition.

Subpoenas 130

Subpoenas Discovery Depositions Objections 130

E-Discovery LLC

AUGUST 16, 2024

The identification of non-custodial sources of data is a foundational issue, and you don’t get to make an objection to the other side’s disclosure and then hold on to that objection forever and ever, and years later ask to start the whole process over from scratch. We’re not starting this over from the beginning.

Discovery 130

Discovery Interrogatories Depositions Litigation 130

E-Discovery LLC

APRIL 18, 2025

Defendant contends this document dump served no other purpose than to obstruct MJCs review process … and impede [its] ability to prepare for … deposition scheduled April 4th. Rule 34(b)(2)(D) states that: The response may state an objection to a requested form for producing electronically stored information.

Objections 130

Objections Discovery Depositions Court Rules 130

E-Discovery LLC

OCTOBER 17, 2024

They also sought the former attorney’s deposition regarding the alleged offer. When it came to the request for a deposition , the court wrote: Lastly, Plaintiffs request a deposition of former Town Attorney Nugent in connection with his role in making the alleged quid pro quo as outlined in Plaintiffs’ motion papers.

Discovery 130

Discovery Depositions Interrogatories Settlement Negotiations 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. 1, 2023)( untimely discovery objection was waived); cf. The court will deny Fiskars’ motion for this reason alone.

Interrogatories 130

Interrogatories Discovery Objections Counterclaim 130

E-Discovery LLC

APRIL 15, 2025

Defendant contends this document dump served no other purpose than to obstruct MJCs review process … and impede [its] ability to prepare for … deposition scheduled April 4th. Rule 34(b)(2)(D) states that: The response may state an objection to a requested form for producing electronically stored information.

Discovery 130

Discovery Objections Depositions Court Rules 130

The Cloud Court Blog

OCTOBER 26, 2022

Over the years I’ve attended a lot of depositions. When the deposition is over, the people that were in the room often have a sort of inexplicable, Venn-type diagram of disparate recollections about what actually happened. But now, as my team has continued to study depositions, I've come to suspect that something else is at play here.

Depositions 52

Depositions Witnesses Exhibits Objections 52

E-Discovery LLC

MARCH 8, 2025

The court wrote that it then adopted Defendants protocol [as an order] and no objection to that order was filed. See Too Busy to Respond to Discovery = Waiver of Objections & Sanctions (Nov. Mistake #3: On January 2, 2025, [1] Plaintiff objected to the Magistrate Judges December 23, 2024, decision. [2] See 28 U.S.C.636(b)(1)(fourteen

Discovery 130

Discovery Objections Interrogatories Litigation 130

E-Discovery LLC

DECEMBER 19, 2024

Plaintiffs later noted the deposition of a non-party, Dr. Fanning on March 29, 2024. Objections were due by July 10 th. Fanning and well before the deposition. Plaintiffs contended that SCA did nothingsuch as objecting or filing a motion to quashsince it received notice of the Subpoena.

Depositions 130

Depositions Subpoenas Evidence Discovery 130

E-Discovery LLC

MAY 30, 2024

PNI objected to discovery in part by asserting several privileges. After document was used in a deposition, PNI sought a “clawback” under the ESI Protocol. Moreover, the delay prejudices Resolve as it attempts to complete depositions and other discovery without the benefit of documents to which it may be entitled. 565, 577 (D.

Discovery 130

Discovery Depositions Objections 130

E-Discovery LLC

DECEMBER 16, 2024

Etame did not appear for his deposition on March 10, 2022. Nguhs motions, but held the sanctions motion in abeyance, and ordered Mr. Etame to appear for deposition. After the parties discussed scheduling, Mr. Etame failed to appear for deposition. As a result, Ms. Nguh filed a motion for sanctions for his failure to appear.

Discovery 130

Discovery Interrogatories Affidavits Pleadings 130

Planet Depos

OCTOBER 30, 2024

It is the very reason you hire a court reporter for your deposition. Each participant in the deposition can aid in reaching the goal of a timely, accurate transcript. Each participant in the deposition can aid in reaching the goal of a timely, accurate transcript. Every court reporter works efficiently toward this goal.

Depositions 81

Depositions Exhibits Witnesses Objections 81

E-Discovery LLC

AUGUST 13, 2024

Next, the undersigned specifically directed the parties to identify a timetable for completion of all discovery, including taking any depositions. ( Regarding depositions, the undersigned cautioned Plaintiff that if she wanted to take any depositions, she was to communicate with the Defendant’s counsel about the same. (

Discovery 130

Discovery Depositions Interrogatories Objections 130

E-Discovery LLC

JANUARY 27, 2025

A dispute arose over the application of the ESI Order and: Meta wants to clarify that the requesting partys opportunity to object to the sufficiency of the producing partys original and new search terms is triggered only if the producing party identified responsive documents in the null set sample.

Discovery 130

Discovery Objections Depositions 130

Attorney at Work

SEPTEMBER 15, 2022

Offering a legal service is, of course, quite different from developing a new disinfectant, or building a software application or a material object. They can also monitor accepted settlements, tracking any pending payments, recording any deposited checks, and projecting any future income streams. A Powerful Project Management Panacea?

Trial Preparation 271

Trial Preparation Case Management Litigation Discovery 271

E-Discovery LLC

AUGUST 31, 2024

These videos were admitted into evidence without objection and were contained in about 30 video exhibits. Over objection, Lieutenant McDonald testified that he focused on one of the suspects who wore distinctive attire. The court admitted the composite video over objection. before the shooting; on Pleasant Street at 12:17 a.m.

Admissibility 130

Admissibility Exhibits Evidence Cross-Examination 130

E-Discovery LLC

APRIL 10, 2025

In my opinion, one factor that should be considered in these discussions is how the produced communications can be used in depositions, motions, and at trial. The adverse party may do so over a hearsay objection. In each instance, one may reasonably ask what is the document? Fed.R.Evid.

Discovery 130

Discovery Evidence Litigation Objections 130

E-Discovery LLC

JANUARY 15, 2025

Plaintiffs asserted, however, that Defendant insists on keeping its relevant custodians and data sources to itself (or at least forcing Plaintiffs to try and discover the same through interrogatories and depositions). emphasis added]. The Zarfati court then published an ESI Protocol. at *5, passim.

Discovery 130

Discovery Interrogatories Objections Depositions 130

E-Discovery LLC

JANUARY 8, 2025

Reliance on Rule 33(d) is appropriate when the interrogatory requests objective facts that are obvious from the specified documents, but is generally inappropriate when the interrogatory asks a party to state its contentions or to state facts supporting its allegations.

Interrogatories 130

Interrogatories Discovery Depositions Objections 130

Plaintiff Trial Lawyer Tips

JANUARY 15, 2025

They just launch off without any particular objective other than an impeachment they have available. We need specific focused objectives thought out and planned in advance. My cases involve depositions that are all video taped. You can show excerpts from the expert deposition video if available. Apply Psycho Drama.

Cross-Examination 113

Cross-Examination Witnesses Direct Examination Depositions 113

E-Discovery LLC

AUGUST 21, 2024

See Felder Part 2 of 4: Defendant Sanctioned for Late Cancellation of Depositions. Giant objected….”); Steamfitters Loc. By then, the video had been overwritten. This is the third of a four-part blog on Felder , an employment discrimination case. Giant of Maryland, LLC , 477 Md.

Evidence 130

Evidence Discovery Objections Litigation 130

SW&L Attorneys Blog

MARCH 15, 2025

A failure to provide the requested information without valid objections may result in a motion to compel, a procedural mechanism through which a party seeks judicial intervention to enforce compliance. The opposing party may object to discovery requests by asserting that the information sought is cumulative, duplicative, or unduly burdensome.

Discovery 52

Discovery Interrogatories Depositions Witnesses 52

The Cloud Court Blog

SEPTEMBER 28, 2022

I am obsessed with depositions and, in particular, their importance to the outcome of cases. That obsession extends to deposition data as well as to the psychology of the players involved: the attorneys taking and defending depositions; the witnesses being deposed; as well as the court reporters. Why on earth would we do this?

Litigation 52

Litigation Depositions Witnesses Motion Practice 52

The Cloud Court Blog

FEBRUARY 24, 2023

It began as a series of reports combined into a dashboard that provided insights about deposition transcripts. Now, Gibson is more than a tool; it’s a partner for any litigator that augments their ability to devise deposition strategies and tactics and improve outcomes. (We

Depositions 52

Depositions Cross-Examination Witnesses Litigation 52

Planet Depos

NOVEMBER 24, 2024

Whether taking a deposition in person or remotely, having a clear record is essential for use at trial, possible settlement and/or impeachment. Ask the witness (or the interpreter if one is present) to sit next to the court reporter to ensure he/she can both see and hear the witness/interpreter (for in-person depositions).

Witnesses 52

Witnesses Depositions Exhibits Objections 52

WA Bar News

NOVEMBER 12, 2024

Humphries stipulated to suspension for: 1) failing to reasonably consult with clients about the means by which the clients’ objectives were to be accomplished; 2) providing legal services to clients, without their informed consent, confirmed in writing, to conflicts of interest created by Respondent’s representation. Diligence ), 1.4

Depositions 52

Depositions Objections Mediation Court Rules 52

SW&L Attorneys Blog

NOVEMBER 8, 2024

Stashing Physical Cash or Valuables: Assets like cash, jewelry, or collectibles are sometimes hidden in safety deposit boxes, with friends or family, or in obscure locations to avoid being accounted for. This reduces income on record, lowering obligations for spousal support or shared property distribution. In Bollenbach v.

Finance and Banking 92

Finance and Banking Subpoenas Litigation Evidence 92

The Cloud Court Blog

AUGUST 17, 2022

How do you overcome these aphoristic objections? Suppose you have a matter where you’re noticed for several depositions. Within a few months, every litigation attorney is having the app ride shotgun in every deposition – taking and defending. That is: “If everyone can’t use it, no one can use it.” Start small and expand.

Depositions 52

Depositions Objections Litigation Witnesses 52

Percipient

SEPTEMBER 29, 2022

When lawyers prepare for litigation, depositions, mediations, or even internal investigations, they conduct a document review to find all the documents related to the project. Review Guidelines The review guidelines section details the actual scope of the project and clearly states the objectives while including coding instructions.

Objections 52

Objections Mediation Pleadings Depositions 52

E-Discovery LLC

OCTOBER 6, 2024

It noted that Mr. Shapiro even testified during depositions that he could not identify a single email that anyone read. The technology consultant was not identified as an expert for either side, but, without objection from Mr. Shapiro, HHI offered the consultant’s affidavits in support of its motion for summary judgment.

Evidence 130

Evidence Litigation Discovery Affidavits 130

The Cloud Court Blog

FEBRUARY 9, 2022

Shifting a culture toward innovation means de-emphasizing checklists and focusing only on the most important handful of objectives. If you or your litigation team have an initiative to look for ways to improve deposition performance, accelerate resolutions, or achieve better outcomes, contact us and request a custom demo.

Depositions 52

Depositions Objections Litigation Technology 52

WA Bar News

APRIL 14, 2025

Although fact witnesses who are subpoenaed for a deposition or trial are entitled to statutory witness fees, those are modest in both state and federal court and usually do not compensate the witness fully for the time involved. 3 In this column, we will first briefly survey the development of RPC 3.4(b) b) in Washington for context.

Witnesses 52

Witnesses Depositions Evidence Real Estate 52

MyCase

JUNE 5, 2024

CLM tools are designed to make traditionally static contracts more accessible and valuable, enabling the use of datasets to inform decision-making and support key business objectives. Who uses them: In-house counsel; sometimes larger law firms. Who uses them: Litigators and appellate lawyers.

Litigation 52

Litigation Legal Research Technology Depositions 52

MyCase

NOVEMBER 2, 2020

And the second thing is the willingness of courts and practitioners to adopt the obvious, which is to have depositions remotely, and to have all the parties remote. But a month later, there I was doing depositions online, dozens of them, with attorneys who had previously objected to them. We often could speak.

Energy and Utilities 98

Energy and Utilities Depositions Education Technology 98

Evidence at Trial

APRIL 26, 2023

In California, evidence is comprehensively defined to include "testimony, writings, material objects, or other things presented to the senses that are offered to prove the existence or nonexistence of a fact." What Social Media Evidence? Starting with the obvious, information on social media certainly is evidence. Code § 140.

Evidence 52

Evidence Admissibility Witnesses Chain Of Custody 52

WA Bar News

JULY 10, 2024

Although the court denied the motion, it was only after depositions of the personnel involved and an evidentiary hearing involving outside counsel. When this all tumbled out later in the wake of the client’s deposition, the firm was disqualified for improper invasion of the opponent’s privilege. citing Daines , cross-referencing RPC 5.3,

Legal Services 52

Legal Services Technology Depositions Privileged Communication 52