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Request for Production of Files of the Adverse Expert

Request the Files of the Expert Before the Deposition

Long before you take the deposition of the adverse expert you should serve a request for the files and records of the expert. You need those files of the adverse expert witness to determine if you really need to take the deposition. You need to decide whether a deposition by you will show the other side how strong their expert is, in a case that is going to settle before trial? Will a deposition by you hurt you by preparing their expert to better withstand your cross-examination at trial?

Are you really going to be learning anything by taking the deposition? You need the adverse expert's files before you decide to take his/her deposition.

Subpoena Duces Tecum to Adverse Expert Witness

“Don't let the deposed adverse expert smile because you did not serve a solid subpoena duces tecum.”

The 17th century subpoena form that lawyers and clerks still use does not give you maximum power in a 21st century adverse expert's discovery deposition. So – create The 21st Century, Advanced Strength Subpoena Duces Tecum by adding some additional needed paragraphs.

Instruction Form for Witnesses – Improve Testimony

Deposition & Trial Testimony – Witness Preparation Instructions: (“Pointers for Witnesses”)

“Prepare your witnesses to testify effectively! Give your witnesses take-home testimony instructions that they can review several times.”

Social Media Checklist, Form, and Deposition Questions

Prepare yourself, client, and witnesses to handle the problems and opportunities that social media sites present for your lawsuit.

Chances are good that your client, the adverse party, witnesses on both sides, and the potential jurors have comments about themselves — their prejudices – and even about the events and damages in litigation. You need to proactively protect your client and witnesses. You need to ask the right questions about social media sites when you take depositions of adverse witnesses. That's why we provide the Social Media Tips and Checklists Suite of forms and checklists.

Motion for Protective Order to Block Deposition

Use a checklist style comprehensive motion form to know quickly what to do to stop the adverse party taking a deposition.

To have the court block the deposition, you must work efficiently, and fast, by starting with form motion papers for protective order to quash the deposition.