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 56 - Core Essentials: Preparing Your Clients for Deposition, Part 3 ( The Three Building Blocks of Client Preparation)

Episode #56

In this third installment of our Core Essential series on preparing your clients for deposition, Jim Garrity covers the three building blocks for effective client deposition prep: explaining the deposition process...
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Episode 55: Lessons from the Front Lines: What Not to Do When an Entity Designates Just One 30(b)(6) Witness on A Large Number of Topics

Episode #55

In episode 47, Jim Garrity spoke about the problems you may encounter when entities produce a large number of 30(b)(6) designees on an equally large number of topics (e.g., 29 designees on 30 topics). Today, Garrity...
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Episode 54 - Remember the Errata!

Episode #54

In this episode, Jim Garrity stresses the importance of always reserving the right to review the transcript of your client's deposition testimony, and provides a fresh example from one of his own cases about the...
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Episode 53 - Core Essentials: Preparing Your Clients for Deposition, Part 2 (Helping Them Unlearn Misconceptions)

Episode #53

In this episode, Jim Garrity stresses the importance of beginning your first deposition-specific meeting by understanding what your clients THINK about depositions. What do they think they're for? How long do they...
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Episode 52 - Core Essentials: Preparing Your Clients for Deposition, Part 1 (The In-Depth Interview)

Episode #52

In this episode - the first in a new series on preparing your clients for deposition - Jim Garrity outlines the initial, essential steps for creating invincible deponents. That includes a deep dive into your client's...
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Episode 51 - Core Deposition Essentials

Episode #51

In this episode, we introduce a new line of episodes that will address core essentials of deposition practice, beginning with preparing clients to be invincible witnesses in their depositions.
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Episode 50 - Do You Have A Predictable "Deposition Profile?"

Episode #50

In this episode, Jim Garrity asks you to ponder the predictability of your approach to examining witnesses, such as the order in which you cover topics, and the similarity of your questions from deposition to...
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Episode 49 - A Listener Asks: What if The Examining Lawyer Asks My Witness to Pull Out Her Cellphone and Disclose Texts, Phone Numbers, or Messages?

Episode #49

A listener shared the following scenario with us, and wants to know what to do. Increasingly, and right in the middle of depositions, opposing lawyers ask, "Do you have her phone number?" or "Do you have...
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Episode 48 - For Your Research Files: New Decision on Deposing Witnesses Even When the Adversary Swears They Know Nothing

Episode #48

In this episode, Jim Garrity discusses a brand-new deposition-related decision from the U.S. Court of Appeals for the Eleventh Circuit, whose jurisdiction spans Florida, Georgia and Alabama. The appeals court held...
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Episode 47: A Listener Asks: Can An Entity Designate 29 Separate 30(b)(6) Witnesses for 30 Topics?

In this episode, Jim Garrity takes a question from one of our listeners. The listener served up a 30(b)(6) topic list covering 30 specific topics. in turn, the entity said, it would produce 29 separate designees. Our...
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Episode 46 - Lessons from the Front Lines: What to Do When Your Opponent Notices Their Experts for Deposition Before You Do

Episode #46

Your opponent just served its expert disclosures and reports. You then get a deposition notice - they're going to immediately depose their own experts! And since these depositions may be used at trial - experts often...
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Episode 45 - Objectionable Objections: When Defending Lawyers Claim THEY Don't Understand the Question

Episode #45

There are probably few things more irritating, when examining a deponent, than having the defending lawyers repeatedly interrupt and claim they don't understand your questions. It's bad enough when witnesses feign...
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