Deposition Checklists and Strategies

Hundreds of pattern questions for treating physicians, corporate representatives, insurers, lay witnesses, defendant & others, and annotated with strategic suggestions, pitfalls to avoid, and bonus discovery forms.

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Deposition Checklists & Strategies

REVISION 12 HIGHLIGHTS

Deposition Checklists and Strategies gives you thousands of deposition questions for crucial witnesses: treating physicians, corporate representatives, insurers, experts, defendants, and plaintiffs.

The most recent edition features—

A NEW PRESERVATION DEPOSITION OF PLAINTIFFS’ TREATING PHYSICIAN IN A SLIP AND FALL, TORN ROTATOR CUFF INJURY CASE. This deposition includes plaintiff’s direct examination, defendant’s cross-examination, and plaintiff’s redirect examination, plus commentary and . . .

22 NEW PRACTICE TIPS:

  • The Nature of Preservation Depositions. §3:41
  • The Preservation Deposition as an “Evidence Deposition.” §3:43
  • Respect the Doctor’s Time. §3:45
  • The Importance of Videotape. §3:47
  • The Many Uses of Videotaped Depositions. §3:62
  • How to Act When You’re on Video. §3:71
  • Get the Doctor to Sound Like a Regular Person. §3:73
  • You Should Sound Like a Regular Person Too. §3:81
  • Eliminate the Jargon. §3:83
  • Know When to Shut Your Mouth. §3:85
  • Treating Physicians as Your Best Experts. §3:87
  • When Your Opponent Takes a Preservation Deposition. §3:101
  • Simplifying the Medical Records for the Jury. §3:113
  • Pick Your Battles Carefully. §3:115
  • Obtaining a Preview of Your Opponent’s Case. §3:117
  • Coordination of the Depositions with Other Discovery. §3:131
  • A Strong Ending. §3:133
  • Beware Negatives in Your Questions. §3:151
  • Depositions Never Require Theatrics. §3:153
  • Anticipate Your Opponent’s Preparation. §3:156
  • Time Is Your Most Valuable Resource. §3:158
  • Cross-Examine an Expert, Know the Material. §3:160

And more!

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