Techniques for More Efficient and Productive Discovery
The Discovery Sampler covers discovery basics in civil cases; work product issues; damages; and techniques for effective written discovery and depositions in personal injury, motor vehicle accident, breach of contract, and employment discrimination cases. Some of the highlights include:
Practice-tested, how-to advice and strategies:
- Setting up damages issues with requests for admission;
- Maximizing video depositions for impeachment;
- Using technology to your advantage during the DME’s deposition; and
- Creating and using time-saving deposition checklists as building blocks.
Proven tips for streamlining your discovery practice:
- 3 elements to include in every notice of taking the deposition of an organization;
- 5 items to include in your standard subpoena to create a 21st century, advanced strength, subpoena duces tecum to serve on adverse experts;
- 9 tips and tactics for compelling a nonparty to produce documents;
- 10 ways to save on deposition expenses (and still gain advantages to your side);
- 23 categories of questions for the defendant-driver in a motor vehicle liability deposition;
- 31 categories of deposition questions for the defendant’s accounting expert in a breach of contract case; and
- 38 categories of questions for preparing interrogatories related to the facts surrounding the accident in a vehicular negligence case.