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Privilege Waiver by: Disclosure to Therapist; and, in Rule 30(b)(6) Deposition Preparation

E-Discovery LLC

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. 5, 2024)(Coulson, J.), the Court addressed two important discovery issues. at *2 (emphasis added). Twin Labs, Inc.,

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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.

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Top 5 Tips: Taking Depositions in a Post-Pandemic World

Attorney at Work

While much of the world stopped last year, depositions didn’t. Cases forged ahead and lawyers scrambled to establish new ways of taking depositions and handling proceedings that, for decades, had been routine. But if you follow these five tips, you’ll be ready to handle any deposition that comes your way in the post-pandemic world.

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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 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. GENERAL BIAS 1. Involvement in this Case: (1) HOW BECAME INVOLVED IN THIS CASE (2) INVOLVEMENT WITH EXPERT WITNESS AGENCY?

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Witnesses, Avoid Absolutes

Your Trial Message

By Dr. Ken Broda-Bahm: As they enter a deposition room, or approach the lectern for cross-examination at trial, opposing counsel is looking for an opportunity to make a few memorable points at your witness’s expense.

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Taking Voluntary Depositions of Willing Witnesses in Mexico (Updated for 2024)

Optima Juris

Understanding voluntary depositions in Mexico: A guide for lawyers and paralegals As a lawyer or a paralegal, you may encounter cases where you must schedule a deposition with a witness residing in Mexico. The good news is that conducting a voluntary deposition in Mexico is possible and more straightforward than you might think.