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

EXPERT WITNESS DISCLOSURE It was the Work Group’s impression that many litigants tactically withhold discovery of testifying expert witnesses on the ground that no disclosure is required until a case schedule deadline. That was always the rule if CR 33 (interrogatories) and CR 34 (requests for production) were read.

Depositions 66

Depositions Discovery Objections Exhibits 66

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. You review interrogatory answers and any statements, and cover the issues in the case. This is a recipe for failure.

Depositions 100

Depositions Interrogatories Witnesses Exhibits 100