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

WA Bar News

1, 2024, codify procedure for depositions by remote means. 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. The author has seen items sent after a remote deposition as exhibits that were not what was used.

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Non-Testifying Consultant Subject to Discovery Where Testifying Expert Relied on Consultant’s Work

E-Discovery LLC

Plaintiffs did not disclose the identity of the consultant or the work performed; however, it came out in Dr. Singers deposition. Tesla moved to compel the whole ball of wax identity, a deposition, all documents and communications, invoices, etc. Plaintiff did produce some documentation about the criteria Dr. Singer had developed.

Discovery 130
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CONSIDER A TRIAL CHECKLIST

Plaintiff Trial Lawyer Tips

Once one has a basic trial checklist it can be expanded and modified for specific kinds of cases. Separate checklists can also be created for different time stages pending trial by a series of trial preparation checklists. Index & make summary of relevant information for use at trial. Supplement if needed.

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Project Management Tools for Attorneys

Attorney at Work

One column might be dedicated to deadlines, another to discovery tasks, another to trial preparation. For solo practitioners and small law firms, an application like TrialPad makes trial preparation and organization easy. Communication is no longer siloed between individuals. A Powerful Project Management Panacea?

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OBSERVATIONS ABOUT CROSS EXAMINATION

Plaintiff Trial Lawyer Tips

If the documentation is an deposition the witness gave, you should have that portion noted with the chapter and with page and line number so you are prepared to immediately cite the source and impeach the witness without any fumbling. My cases involve depositions that are all video taped. Apply Psycho Drama.

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Scheduling Orders Are Mandatory; Vital to Caseload Management; and, Enforced Even Where Parties Got Themselves Into a “Pickle” by Dilatory Efforts to Cooperate

E-Discovery LLC

They have taken no depositions…. There have been gaps between emails and meet-and-confers, with little obvious progress made. Aside from agreement on a protective order, discovery disputes appear unresolved…. From the recitation in the joint motion, the defendant has been dilatory.

Discovery 130
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The Ultimate Paralegal Billing Cheat Sheet: Save Time and Avoid Errors

Destination Articles Blog

Replenishable Retainers (Evergreen Retainers): Clients deposit funds upfront, and the balance is replenished as it is used. Retainer fees are often used in family, criminal defense, or employment law. There are certain types of retainer fees.: Instead, break them down: For example, you can consider a drafted motion: 1.5