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 68 -Objecting to the Use of Partial or Incomplete Documents in Depositions

Episode #68

Why do litigators feel comfortable dismembering emails, and showing deponents only fragments of the actual conversation? More importantly, why do they think it's okay? In this episode, Jim Garrity discusses "rule of...
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Episode 67 - Do Deposition Subpoenas Expire?

Episode #67

In this episode, Jim Garrity addresses the question whether your deposition subpoena, which contains a specific date and time for appearance, in fact expires (requiring the witness to be re-subpoenaed) if the...
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Episode 66 - Something to Know About Our Show Notes: We're Constantly Adding to Them

Episode #66

Did you know? Our show notes - where we list the cases and other authorities on which each episode is based - are dynamic. That means we're constantly updating and adding to them. As we encounter new cases in our...
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Episode 65 -Who's Zoomin' Who? Identifying Your Remote Deponents' Off-Screen Cheat Sheets

Episode #65

What exactly have your remote video deponents placed in front of them - on their screen, on the floor, on sticky notes, on a second monitor and elsewhere - to help them testify and spew the official line? Do you...
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Episode 64 - Proving "Unavailability" in Order to Use Depositions at Trial

Trial is approaching, and you learn a witness you planned to call live now isn’t available. You'll need to read or play their deposition testimony instead. That means that you must prove the witness' "unavailability"...
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Episode 63 -About That Pesky Notice Language (For Use in Discovery "And/Or At Trial")

Episode #63

In this episode, Jim Garrity explores the effect of language added by many litigators in their notices that the deposition may be used (apart from discovery purposes) at trial, in lieu of live testimony by the...
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Episode 62 -A Tool for Motivating Deponents to Reveal What They Know, Without Fearing Retaliation

Episode #62

In this episode, Jim Garrity shares a valuable tool for protecting the identities of nonparty deponents and, in the process, protecting their careers, reputations, and families. A deponent who sees that you've taken...
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Episode 61 - Lessons from the Front Lines: A Judge’s All-In-One Guide to the Right (and Wrong) Way to Make Deposition Objections

Episode #61

In this Lessons from the Front Lines episode - where we review brand-new deposition-related cases from around the country - Jim Garrity discusses a new ruling that belongs in your research files (and in your briefcase...
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Episode 60 - Core Essentials: Preparing Your Clients for Deposition, Part 7

Episode #60

In this episode, Jim Garrity concludes the Core Essential Series on preparing your clients for depositions by discussing additional topics to cover with your clients, including the possibility of questions about...
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Episode 59 - Core Essentials: Preparing Your Clients for Deposition, Part 6

Episode #59

In this episode, Jim Garrity continues the series on preparing your clients for depositions. He’ll wrap up this series in the next segment. Today's episode includes pointers to share with your clients about the...
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Episode 58 - Core Essentials: Preparing Your Clients for Deposition, Part 5

Episode #58

In this episode, Jim Garrity shares additional critical insights for preparing your clients for deposition. Today's episode includes pointers to share with your clients about how judges, opposing lawyers, and juries...
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Episode 57 - Core Essentials: Preparing Your Clients for Deposition, Part 4

Episode #57

In this fourth installment of Preparing Your Clients for Deposition, Jim Garrity begins sharing critical insights you need to tell your clients about the deposition process: the layout of the room where the deposition...
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