News & Analysis as of

Trial Preparation Rules of Civil Procedure

Esquire Deposition Solutions, LLC

Remote Deposition Convenience Doesn’t Defeat Forum Shopping Objections

The convenience and widespread use of remote depositions and virtual hearings will not, in seems, make it any easier for plaintiffs to choose what they believe is the most advantageous forum for litigating their cases....more

Butler Snow LLP

A Sort of Homecoming: Preparing and Defending the Sales Representative Who Is No Longer with the Company

Butler Snow LLP on

A high school reunion can be a wonderful, surreal experience at best, and a handwringing, anxiety-ridden event at worst. During those formative years of our teenage lives, we were surrounded by – and spent countless hours...more

Esquire Deposition Solutions, LLC

Recent Rulings Highlight Importance of Depositions in Litigation

In civil litigation, depositions are a key pretrial discovery tool used to uncover facts, obtain admissions, gather evidence for motions, and assess witnesses. They prevent “trial by ambush” by revealing crucial information...more

Butler Weihmuller Katz Craig LLP

Sweeping Changes to Florida Rules of Civil Procedure

The Florida Supreme Court recently approved significant amendments to the Florida Rules of Civil Procedure. ...more

Esquire Deposition Solutions, LLC

Skip Your Deposition and Pay the Price?

We’ve written previously about sanctions that trial courts can impose on parties that, for no good reason, fail to appear for a properly noticed deposition. Courts are understandably impatient with parties that throw sand in...more

Esquire Deposition Solutions, LLC

Massachusetts High Court Proposes Detailed Rules for Remote Depositions

The Massachusetts Supreme Judicial Court recently released for public comment a proposal to create a baseline set of ground rules for the conduct of remote depositions in that state. The proposed rule revisions would set out...more

Hendershot Cowart P.C.

Texas Rule 202: The Advantages of Pre-Suit Depositions in Litigation

Hendershot Cowart P.C. on

Rule 202 refers to the pre-suit deposition rule in the Texas Rules of Civil Procedure. This rule allows a person or party involved in a dispute to request deposition – sworn testimony recorded by a court reporter – to...more

Esquire Deposition Solutions, LLC

New York Courts Weigh Improvements to Pretrial Conferences

In theory, pretrial conferences streamline litigation by setting discovery deadlines and encouraging parties to take a hard look at all relevant issues in the case and, if possible, reach a settlement before trial....more

Esquire Deposition Solutions, LLC

Courts Want to See Just the Relevant Portions of Deposition Transcripts

In the federal system, deposition testimony often provides crucial evidentiary support for summary judgment motions— a key procedural device for narrowing contested issues that require trial or, in some cases, eliminating the...more

IMS Legal Strategies

What Are the Standards and Procedures for Jury Selection in My Jurisdiction?

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As a national trial consulting firm, we are often asked to assist with jury selection in jurisdictions where lead counsel has been admitted pro hac vice and may not be closely familiar with the standards and procedures for...more

Esquire Deposition Solutions, LLC

Texas on the Verge of Adopting Interstate Depositions Law

Ever since the Uniform Law Commission published the Uniform Interstate Discovery and Depositions Act in 2007, the disinterest among Texas lawmakers to adopt the law has been both a curiosity and, to a small extent, a failure...more

Esquire Deposition Solutions, LLC

Before You Press “Record” on a Zoom Deposition

If you’ve ever wondered whether it’s possible to create a “video deposition” merely by recording a Zoom call, you’re not alone. After all, the litigators and witnesses, and the court reporter, are present, their voices and...more

Farrell Fritz, P.C.

Commercial Litigation in New York State Courts, 5th Edition Chapter 39, “Practice Before the Commercial Division”: A Review

Farrell Fritz, P.C. on

As frequent readers of this blog are no doubt aware, the ten-volume practice treatise entitled Commercial Litigation in New York State Courts and edited by distinguished commercial practitioner Robert L. Haig (the “Haig...more

Farrell Fritz, P.C.

Rule Change Alert: Readability Is Key For Responsive Pleadings Under New Rule 6 (d)

Farrell Fritz, P.C. on

As practitioners and readers of this blog are aware, responsive pleadings are foundational documents prepared at the earliest stage of a litigation in which the responding party denies, admits, or states that she lacks...more

Esquire Deposition Solutions, LLC

The Role of Depositions in Preserving Trial Errors for Review

Whether it’s during a deposition or during trial, the job of preserving errors for judicial review is a vital part of the litigator’s professional obligation to his or her client. Many trial outcomes turn on evidentiary...more

Holland & Hart - Your Trial Message

Don’t Practice til You’re Capable, or til You’re Comfortable — Practice til You Can’t Fail

My daughter is a figure skater — the kind of skater who practices six days a week. Each one of the complex jumps that a skater executes involves dozens of fine-motor movements that need to be encoded into the skater’s muscle...more

Latham & Watkins LLP

Remote Evidence in English Courts: Some Timely Reminders

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Parties seeking to rely on video-link evidence should plan ahead and, where necessary, obtain local and foreign court approval. The COVID-19 pandemic has (albeit by necessity) ushered in a move towards remote justice. The...more

Troutman Pepper

The Nuts And Bolts Of Local Practice In The Eastern District Of Michigan (Part 3): A Guide To Practicing In The U.S. District...

Troutman Pepper on

A civil jury trial is a risky proposition in any court, state or federal. To manage that risk, it is usually in each party’s interest to engage in some form of alternative dispute resolution, or ADR. Knowledge of the local...more

Troutman Pepper

The Nuts And Bolts Of Local Practice In The Eastern District Of Michigan (Part 2) - A Guide To Practicing In The U.S. District...

Troutman Pepper on

As in the Michigan state court system, most of your time in a federal civil case will be spent on discovery, and most of your interaction with the court will be through motion practice. Different courts have different rules...more

Reveal

Using Video Deposition Testimony for Opening Statements & Closing Arguments

Reveal on

Trial advocacy is a mix of law and theater, requiring a lawyer to know both the law and their audience. Attorneys must effectively argue their client’s case using the evidence and the jury instructions to show their client is...more

Jaburg Wilk

Navigating the Rapids - Temporary Orders Hearings in Maricopa County

Jaburg Wilk on

One of the most anxiety-producing experiences for both a family law client and their attorney is navigating through the process relating to a Maricopa County temporary orders hearing. The client’s anxiety is easy to...more

Hogan Lovells

New disclosure rules: evolution or revolution?

Hogan Lovells on

A pilot scheme to introduce extensive reforms to the English court disclosure rules has been approved in principle by the Civil Procedure Rules Committee (CPRC, the body responsible for approving civil court rule changes). ...more

Hogan Lovells

How a constitutional amendment is transforming litigation in Mexico

Hogan Lovells on

In 2017, Mexico’s congress approved a key amendment to its Federal Commercial Code. The amendment is now driving dramatic changes to the country’s trial process. One of those changes — a shift from written to oral proceedings...more

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