Tag Archives: Depositions

#2 Pretrial Agreements – Depositions Procedures

Depositions Will Be Taken by Agreement and Will Be Limited in Number and Length. Some counsel try to gain an advantage by unilaterally noticing depositions or by overstrategizing the issue of whose witnesses will be deposed first.  These issues tend to waste time while having no impact on the outcome of a case. The parties should agree at the beginning of the case that depositions will be taken by agreement, with no unilateral deposition notices.  Moreover, the parties should agree to alternate witnesses – plaintiffs’ witness first, defendants’ second, plaintiffs’ third, defendants’ fourth etc. Lawyers tend to take too many …


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