Electronic evidence, discovery, and ESI tips, law, tactics.

Power Litigation™

Tips and tactics to improve performance. Office and case organization and helpful hints and checklist for depositions, discovery, negotiations, and trial.

Litigation-tested tactics and strategies. Not only tips and proven tactics in these articles. The following also include forms for your office and trial notebook. They increase your productivity, and maximize your advantages, in discovery, settlement, and trial.

"Making Good Lawyers Better." That is the prime reason for our constant addition of more items for you to read and use!

Although some of the following linked items carry a nominal charge to download, many of the following links take you to free forms and free articles on litigation tactics or on case and office management. Browse, Read, Download.

Three commandments for your oral motion argument.

What is a "Total Loss" vehicle?

Handling the "I don't know" response

Expert witness can testify on ultimate issues in negligence case.

Standard cross-exam questions.

Fixing the problem if you miss a litigation deadline.

Ethics of witness preparation.

Terminating representation of client - 6 page checklist.

Practical tips for improving your negotiations.

Instructions to your expert regarding his/her report.

Organization Wins! in Litigation.

Why use a checklist for asking questions at a deposition?

Patient's right to get changes made in the medical record.

Motion in your pocket to prevent the taking of a deposition.

Dealing with Rambo on conference summaries.

Claim for first-party insurance claims preparation expense.

Discovery of expert's communications with attorney

The "Always Ask" block of eight deposition questions.

Voir dire question content worksheet for attorneys.

Three items to form a base for better negotiation.

Why you should emphasize something in every deposition.

Persuader's Real Rules of Exhibit Evidence

Two things to do in every deposition.

Reading deposition into evidence


Power Litigation™: Electronic evidence, discovery, and ESI tips, law, and tactics.

Electronically stored information (ESI) use, discovery, and evidence is the subject of today's most rapid changes in the law.

Our intent is to provide information which will increase your productivity, and maximize your advantages, in discovery, settlement, and trial -- when ESI is involved. Here are tips, tactics, and strategies for the discovery and use in litigation of electronically stored information.

Spoliation Motion? Before arguing, read these two cases.

Social media pages, checklist, form, deposition questions.

Emailing client at work? Danger ahead!

Black box data in the car: motor vehicle crash EDR.

Electronically Stored Information: spoliation prevention.

What the judge expects you to know about keywords and ESI.

Avoid use of "All" in ESI discovery requests and disclosures.

There's hard drive ESI storage in most copiers and printers.

Taking judicial notice of a fact found on the Internet.


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