Depositions Discovery Exhibits 
Complex Discovery
JUNE 7, 2025
Modern corporations often exhibit similar patterns, with departments sharing information upward to senior management while maintaining limited cross-functional communication. This vertical orientation creates what researchers term “silos”—isolated organizational units that operate with minimal coordination or knowledge sharing.
WA Bar News
NOVEMBER 12, 2024
They will require a material change in the way many attorneys practice discovery. 1, 2024, codify procedure for depositions by remote means. Except for special proceedings, a case schedule deadline to disclose experts does not excuse a party from timely responding to expert discovery to the extent responsive information is available.
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Planet Depos
DECEMBER 15, 2024
There are countries that do not allow taking depositions for a number of reasons. This can obviously lead to numerous discovery problems that can make or break a case. So, what do you do if you need to depose a witness who resides in a country where depositions are not permitted? Pay for the witness travel.
Plaintiff Trial Lawyer Tips
OCTOBER 17, 2024
“By failing to prepare, you are preparing to fail” Benjamin Franklin In our office, my law partner and wife, Lita Barnett Luvera, legal responsibilities included preparing clients and witness for their deposition. Too often, lawyers tend to schedule an hour or two in their office on the day of the deposition to prepare their client.
Plaintiff Trial Lawyer Tips
OCTOBER 31, 2024
THREE PRIMARY DEFENSE CLAIMS __ __ __ PLAINTIFF PROOF OF CAUSATION __ DEFENDANT CAUSATION DEFENSE _ PRELIMINARY STATUS REVIEW Review local rules regarding deadlines and requirements DISCOVERY REVIEW Interrogatories Review defendant’s answers to interrogatories. Note incomplete answers for motion. Laptop, I-Pad, projectors etc.
E-Discovery LLC
AUGUST 13, 2024
The Court “presided over a discovery dispute hearing related to Plaintiff’s motions to compel interrogatory requests and requests for production of documents, and related to a motion for a protective order filed by the Defendant.” Sometimes Discovery Disputes Do Not Bring Out the Best in Us – Part II (Jun. 7, 2024)(Simms, J.),
E-Discovery LLC
AUGUST 31, 2024
These videos were admitted into evidence without objection and were contained in about 30 video exhibits. Importantly, the Court wrote that: “We do not interpret the rule to require a party to include their adversary’s version of the facts in their summary exhibit.” Second, attached as Exhibit 8 is a Digital Video Disc (“DVD”).
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