The July, 2008 issue of Trial Magazine is devoted to "Trial Techniques" and contains an article by Elliott Wilcox titled "Sifting the issues with stipulations." (AAJ membership required unfortunately, or get it at the library.)
It's an article that's equally useful to lawyers for the plaintiff or defense. Wilcox examines stipulation on the following issues:
- Prior deposition testimony;
- Authenticity of documents or business records;
- Other evidentiary foundations;
- Stock photos and diagrams;
- Sworn statements in lieu of live testimony;
- Percentages of fault or loss;
- Witness credentials;
- Admissibility of demonstrative exhibits;
- Allowing witnesses to testify by alternative means;
- Allowing witnesses to testify out of order;
- Technical and scientific literature;
- Suspending standard testimony requirements;
- Indisputable facts.
Other articles in the trial-techniques issue of Trial include "What can a mock trial tell you?" by Anne W. Reed, "Shield your client from defense attacks," by Cindy L. Nations, and "Direct examination of lay witnesses," by Charles G. Monnett III and Randall J. Phillips.