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Two things to do in every deposition
Introducing Exhibits at Depositions; Asking for Specifics of Objections At depositions, of your witness or theirs, there are two actions you almost always should take (whether you represent the deponent or are adverse to the deponent). If a physical or … Continued
Three items to form a base for better negotiation
Three items that can form a basis for settling your lawsuits – better and faster. Effective negotiation and mediation call for advocacy skills and advocacy – style presentations. Losing lawyers don’t do a really persuasive presentation before reaching the settlement … Continued
Three commandments for your oral motion argument
Oral arguments to the motions judge: Your three commandments Commandment # 1. In the first three or four sentences of your oral argument you will state the factual or procedural situation. You may be working with a complicated situation. But … Continued
There’s hard drive storage in most copiers and printers
This following complimentary form or article is a result of our mission statement: “Making Good Lawyers Better.” Thank you for being a lawyer! TIP4550 Be Aware of the Evidence that may be in MFP’s Our message involves mostly a security … Continued
There’s a Black Box in your client’s car
This is a PowerLitigation™ article of Leonard Bucklin. This article was adapted for LawyerTrialForms™ from his multi- volume text of discovery, litigation, and trial advice and tactics, titled Building Trial Notebooks. Bucklin is a Fellow of the International Academy of … Continued
The first ESI mistake to avoid
The first ESI mistake to avoid — and a list of “to do’s” to avoid it Chronologically, the first ESI mistake to avoid is failing to tell the client, (A) early and (B) clearly, that the client must preserve existing … Continued
The Ethics of Witness Preparation
Power Litigation™ – Preparing the Witness to Testify: the legal ethics, and how to do it ethically. As part of our free publications of useful litigation materials for lawyers and legal assistants, we offer the following summary of the legal … Continued
The “Always Ask” block of eight deposition questions
The following is a block of eight questions you should always ask at a deposition of an adverse or independent witness. The witness’s answers may be startling to you and damaging to your opponent. We call this the “Always Ask” … Continued
Terminating representation of client checklist
In the best of litigation practices, there comes a time when you realize that a client is not responding to your requests, is hiding evidence, is not paying your bills, or is simply a lying, rude, nasty person that you … Continued

