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 20 - Apex Depositions

Episode #20

You need to depose a high-ranking government or corporate official, but their lawyer refuses, saying the official is protected by the Morgan Doctrine, sometimes called the Apex Doctrine. This principle stands for the...
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Episode 19 - Lessons from the Front Lines: 922 Deposition Objections. (Then Sanctions Happened.)

Episode #19

In a November 30, 2020 Memorandum Order, a federal judge imposed sanctions against a lawyer for alleged excessive and improper objections during depositions. According to the Order, the defense attorney was accused of...
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Episode 18 - The New Change to FRCP 30(b)(6), Effective December 1, 2020

Federal Rule of Civil Procedure 30(b)(6) - the subsection that allows you to compel an organization to produce a representative who can testify knowledgeably about topics you selected - has just been amended....
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Episode 17 - Can You Ask the Same Questions In Depositions That You Just Asked (And Got Answers To) In Interrogatories?

Courts have been ruling on the question for years: Is it proper to ask the same questions in depositions that you just asked (and received answers to) in interrogatories? In this episode Jim Garrity definitively...
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Episode 16 - Contesting Excessive Expert Deposition Fees

Episode #16

What to do when you reach out to schedule an opponent's expert witnesses for deposition, and are told that you've got to pay the experts an outrageous hourly-rate or flat-rate fee (in advance) before they'll appear? ...
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Episode 15 - Remote Deposition Protocols for COVID and Beyond

Episode #15

Tired of fighting over protocols for your remote depositions? We've got the solution. In this episode, Jim Garrity discusses a fourteen-page list of protocols negotiated between some of the best lawyers in the world,...
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Episode 14 - Lessons from the Front Lines: Asked and Answered Objections

Episode #14

A November 10, 2020 Discovery Order from a California federal judge says "asked and answered" objections are improper speaking objections. Jim Garrity says the ruling is clearly wrong, because "asked and answered" is...
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Episode 13 - The Real Reason to Cross-Notice A Deposition

Episode #13

Should you cross-notice depositions set by another lawyer? How does cross-noticing benefit you? What's the chief reason you ought to cross-notice a deposition? We give you the scoop on this technical move, and tell...
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Episode 12 - What's the Right Way to Make Form Objections?

Episode #12

You're defending a deposition, and the form of the examining lawyer's questions are improper. What's the correct way to make your form objection? Is it just saying the word "Form"? Or, must you also state the legal...
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Episode 11 - Physical Demonstrations and Re-enactments in Depositions

Episode #11

Many of your lawsuits involve events that can be physically demonstrated or re-enacted. Indeed, your success in pursuing your claims or defenses may depend on the jury's acceptance that an event took place exactly as...
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Episode 10 - Errata Sheet Tips and Traps

Episode #10

Errata sheets - the blank pages that come with a draft transcript for your deponents to use in correcting or changing testimony - serve an important function. But there are five strict requirements for using them, and...
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Episode 9 - Dealing with Cross Beyond the Scope in Depositions

Episode #9

You finished your examination of a witness whose deposition you noticed, and the opposing lawyer - who did not cross-notice the deposition - has launched into a lengthy cross that goes far beyond anything you...
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