Tag Archives: Deposition

What Happens to an Injured Plaintiff who Skips a Deposition and Fails to Hand Over Pertinent Medical History?

Author: EJ Scarillo   Case Citation: Carr v. State Farm Mut. Auto. Ins., 312 F.R.D. 459 (N.D. Tex. 2015).   Employee/Personnel/Employer implicated: Plaintiff who was Involved in a Personal Injury Case     eLesson Learned: Do not dodge discovery requests!   Tweet This: Plaintiff stymies … Continue reading

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Deposition of Unum and Paul Revere Representative Provides Valuable Insight on Unum’s Approach to Determining “Material and Substantial” and “Important” Duties

Under many disability policies, claimants must show that they cannot perform the material and substantial, or the important duties of their occupations in order to qualify for long-term disability benefits.  Although these terms are essential to the determination of a … Continue reading

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“And the Deposition Goes to the Gentleman in the Blue Pinstripe Suit”

Ronen Avraham & William Hubbard, Procedural Flexibility in Three Dimensions (Unpublished draft, 2018). Jay Tidmarsh A burgeoning procedural literature explores the power of parties to alter the procedural entitlements of the civil-justice system by means of contractual agreement and the … Continue reading

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Preparing Your Client for Deposition- Part 13

Before her deposition, your client should understand the legal underpinnings of her case. You should explain to her what is needed for her to win the case and what the other side needs for them to win their case. Go … Continue reading

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Preparing Your Client for Deposition – Part 10

Additional rules of the road for your client for her deposition: 31. Don't take notes during your deposition. The interrogator will you ask you about them. 32. Be careful of questions that use absolutes, like "never" and "always." 33. Don't … Continue reading

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