10,000 Depositions Later Podcast

10,000 Depositions Later Podcast

Hosted by: Jim Garrity

From Jim Garrity, the country’s leading deposition expert, comes this podcast for hardcore litigators. The subject? Taking and defending depositions.Each episode is a one-topic, mini field guide, meant to educate and...

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Episodes

Episode 92 - The Deponent is Taking Notes While Testifying. Can You Demand Them?

Episode #92

In this episode, Jim Garrity ponder the issue whether you're immediately entitled to obtain notes taken by a deponent while testifying or, to go a step further, the notes of non-attorney witnesses observing the...
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Episode 91 - Remote Video Deponents on Cellphones

Episode #91

In this episode, Jim talks about the problems associated with taking document-intensive depositions of remote video deponents who are participating on their cellphones. As always, Jim offers specific practice...
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Episode 90 - So What, Exactly is Impermissible "Coaching" During a Deposition?

Episode #90

In this episode, Jim Garrity explains what constitutes improper coaching during depositions, and offers a wide range of examples. As always, cases mentioned in the episode appear below in the show notes. Thanks for...
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Episode 89 -Lessons from the Front Lines: An Appellate Court’s Ominous Comment to Litigants Fighting Over a Transcript’s Accuracy

Episode #89

In this episode, Jim Garrity discusses an April 18, 2022, opinion from a federal appellate court, about a dispute between the parties over the accuracy of the stenographic transcript of the plaintiff's deposition. ...
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Episode 88 -How to Avoid Being Taxed Costs for Videotaping When Your Opponent Also Arranged for a Stenographic Transcript

Episode #88

Today Jim Garrity offers up 14 different, caselaw-supported, arguments to protect your client from being taxed with an opponent's videographer costs following an adverse case outcome. Many lawyers take for granted...
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Episode 87: Next-Day Certified Transcripts, Rough in an Hour, No Extra Charge: A Conversation with Dean Whalen, Chief Legal Officer of Readback Active Reporting.

Episode #87

Today, Jim Garrity interviews the chief legal officer of a company that offers commodity-priced transcripts with all the bells and whistles of the most expensive traditional court reporters. In the episode, the CLO,...
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Episode 86 - A St. Patrick's Day "Thank You" to 50 Lucky Listeners

Episode #86

No, we can't explain it here! You'll have to listen to find out. It's our way of thanking listeners for making this the top podcast in the country on civil pretrial deposition strategies and tactics!
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Episode 85 - Can You Bluff Dishonest Deponents By Implying You Have Evidence that You Don't?

In this episode, Jim Garrity tackles the question whether you can bluff a dishonest deponent - for the purpose of encouraging the witness to be truthful - by implying you have evidence that actually doesn't exist?...
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Episode 84 - Does the Rule of Sequestration Apply to Depositions?

Episode #84

In this episode, Jim Garrity addresses one of the most widely-held misconceptions about deposition practice. He also provides practice tips when an opposing lawyer "invokes the rule" and demands that one or more of...
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Episode 83 - Lessons from the Front Lines: Alex Jones' Lawyer in the Sandy Hook Case Reprimanded for Deposition Conduct. (He Should Have Listened to Episode #49.)

Episode #83

As you know, our Lessons from the Front Lines episodes spotlight brand-new court rulings from around the country on deposition-related topics. Today's case in the spotlight raises an issue we covered last year in...
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Episode 82 - Testimonial Privileges: The Legislative Privilege

Episode #82

In this episode - the first in a new series this year on testimonial privileges that can impede your efforts to depose witnesses - Jim Garrity explains the "legislative privilege," applicable to legislators and others...
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Episode 81 - How (and Why) to Ask Deponents About Prior Sworn Testimony

Episode #81

In this episode, Jim Garrity stresses the importance of systematically asking deponents to catalogue their prior testimonial experience in any form or forum. A witness' prior testimony can be an intelligence goldmine....
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