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CONSIDER A TRIAL CHECKLIST

Plaintiff Trial Lawyer Tips

Opening statement, witness examination & summation Depositions  Review all depositions & index for access at trial  Create summary of relevant testimony with index to access at trial  Decide how to use at trial. Supplement if needed. Index & make summary of relevant information for use at trial.

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Court Recommends Denial of Rule 37(e)(2) Motion, While Providing Guidance Under Rule 37(e)(1)

E-Discovery LLC

… She estimates that she did this probably a year before her January, 2025 deposition. Further: All attempts to subpoena or depose Mr. Roberts and/or gain access to the text messages through him has been thwarted to date by his evasiveness. Emphasis added]. The Court applied Fed.R.Civ.P. 37(e) to these facts.

Evidence 130