Whose deposition can you take?
Developing a purpose-driven plan for a deposition. Where and when can you take a deposition? Checklist for the formal written notice; putting the witness under oath; and making a record.
Pre-Deposition Negotiations with Your Adversary on Number, Priority, and Relevance of Proposed Depositions.
What witnesses will be deposed, how many depositions will each side
take, who gets to go first with a deposition or series of deposit..
Pre-Deposition Negotiations with Your Adversary on Time, Place, and Compensation for Witnesses with respect to Proposed Depositions.
How to approach the essential issues of amount of time for each deposition, who will be present, what lawyers wi..
Dealing with Aggressive or Hostile Opposing Counsel in Discovery Conferences About Depositions
Ways to defuse the situation so you can have a productive conferring
session; as a younger and perhaps less experienced lawyer, how to deal