First, and most importantly, your major role is preparing your witness. 99% of defending a deposition properly is the preparation. If you prepare your witness properly, you should be able to just be a potted plant . . . . So how do you do that?
This quote is from the middle of the post, which includes a lot of basic information about defending depositions, including some advice for preparing a client for a deposition.
Since I started this weblog in January, 2004, I've written 1,037 posts, enough material for a very large book. Many of these posts are assigned to one or more categories. You can get to these categories by clicking on the list that appears on the left side of the weblog. I've also listed the categories here, followed by the number of weblog posts that have been assigned to each:
James Publishing, which publishes books for lawyers, has started a new Attorney Education Center on its website. The Education Center provides free books and guides, with new titles added each month. Here's what's available now--
There's a lot here for free. For example, Proving Mental & Emotional Injuries,
by John D. Winer, Richard B. Pesikoff, and Richard T. Goldberg, is 1,170 pages long and includes 54 forms. From the website--
This comprehensive title reveals the case workup and persuasion
secrets that the lead author used to turn five low-or-no-offer, pure
psychological injury cases into seven-figure verdicts. Step-by-step, you
will learn how to convince cynical adjusters, defense attorneys,
judges, and jurors of the reality and seriousness of mental and
emotional injury cases.
§4:255 Practice Tip: What the Expert Did Not Do
Remember to ask the expert not only what he did to prepare himself to render an opinion, but what he didn’t do. Of course, you cannot come right out and ask, “Please tell me what you failed to do in rendering an opinion.”
Instead, ask the expert whether he did or didn’t do specific things.
[A] team composed of specialists in neurology, psychology, and rehabilitative medicine at Emory University have recently looked at the curious ability of some metaphoric language to be processed not just in the speech regions in the brain, but in those associated with bodily action as well.
Read the full post for some interesting thoughts about "llitigation uses of tactile metaphoric language."