LET S GO TO THE VIDEOTAPE! Using Video Depositions at Trial By Andria Simone Kelly, Esq.

Size: px
Start display at page:

Download "LET S GO TO THE VIDEOTAPE! Using Video Depositions at Trial By Andria Simone Kelly, Esq."

Transcription

1 LET S GO TO THE VIDEOTAPE! Using Video Depositions at Trial By Andria Simone Kelly, Esq. The Power of Visual Presentations A videotaped deposition that is thoroughly, properly and effectively conducted can prove to be a very persuasive tool at trial. Not only does it serve to preserve live testimony in the event a witness becomes unavailable, but it can also be extremely powerful when impeaching the testimony of the deponent as a witness. Almost every article on the use of videotaped depositions at trial quotes the old adage: A picture is worth a thousand words. Clearly, the actions and inactions of a witness during a deposition are not seen when the traditional deposition transcript is read at trial. Changes in tone or volume of voice, pauses or hesitations, eye rolls or sideways glances, shaking or nodding of the head, looks of horror, affront or disgust, and simple body movements or language cannot be discerned by listening to an attorney read the witness testimony from a deposition transcript. Thus, deposition testimony that is merely read aloud sounds hum-drum to the judge and the jury alike and does not serve the same punch as if it were presented via video. The reality is that jurors, especially young, tech savvy jurors, who are forever attached to their cell phones, tablets and other devices, expect that we lawyers are not only moving with the times, but one step ahead of them. Judge McCaffrey said it best as early as 1992 in his decision in Roche v. Udell, 588 N.Y.S.2d 76, 155 Misc.2d 329 (Sup. Ct., Nassau County):

2 It is time to accept the fact that, unlike Judges Chambers where the original Underwood typewriters have only begun to be replaced, even the average country lawyer s office is comparable to a mini-kennedy Space Center with all its state of the art computers, word processors, faxes, Lexis and, now, the latest in video equipment. Thus, suffice is to say video depositions are here to stay for, surer then death or taxes, lawyers like to play with new toys. Id. at 81. Despite Judge McCaffrey s forecast for the future of videotaped depositions, they are still not utilized as much as they should or could be during discovery or at trial. It is common knowledge and simple human nature that individuals will pay more attention to and retain better a video presentation then hearing the written word. We live in a visual age where visual content is a huge part of our everyday lives. Research shows that individuals learn and remember information that they see much better than information that that they hear. In fact, psychiatrist William Glasser has found that we learn and remember 10% of what we read, 20% of what we hear, 30% of what we see and 50% of what we see and hear. Given those percentages it is surprising that there is still reluctance among lawyers to use videotaped depositions over traditional stenographic depositions. Relevant New York Law New York law allows a party to conduct a videotaped deposition without court permission and without showing special circumstance. CPLR 3113(b); see also Roche at 80 citing 3A Weinstein-Korn-Miller, Section pp The Uniform Rules for the New York State Trial Courts, provides for video recording of civil depositions and specifically states: The use of videotape recordings of depositions at trial shall be governed by the provisions of the Civil Practice Law and Rules and all other relevant statutes, court rules and decisional law relating to depositions and relating to the admissibility of evidence. 22 NYCRR

3 CPLR 3117 outlines the rules for the use of depositions at trial. This section applies to stenographic as well as videotaped depositions. Basically, videotaped recordings of depositions, like traditional deposition transcripts, can be used at trial for the purpose of contradicting or impeaching the testimony of the deponent as a witness; for any purpose by any party who was adversely interested when the deposition testimony was given or who is adversely interested when the deposition testimony is offered as evidence; and for any purpose provided the court finds (i) that the witness is dead; or (ii) that the witness is a greater distance than one hundred miles from the place of trial or is out of the state (with some exceptions); or (iii) the witness is unable to attend because of age, sickness, infirmity, or imprisonment; or (iv) that the party offering the deposition has been unable to procure the attendance of the witness with diligent efforts; or (v) upon motion or notice that such exceptional circumstances exist that makes its use desirable in lieu of live testimony. Further, the deposition of a person authorized to practice medicine may be used by any party without showing unavailability or special circumstance. CPLR 3117(a). The videotaped deposition, like the traditional deposition transcript, can be used in the opening statement, during both direct and cross examination and in the closing statement. Best Practices 1) Know the rules! As indicated above, NYCRR is the bible when it comes to the taking, conducting and using of videotaped depositions. Rule discusses objections during and after the videotaped deposition. Objections should be addressed promptly with the trial court. How a trial judge handles objections made during

4 a videotaped deposition or thereafter is in the Court s discretion. Parties should reach an agreement on the videotape deposition testimony they wish to introduce at trial and any objections should be ruled upon by the judge before the trial commences. The bottom line: Follow the applicable rules or risk being precluded from using the videotaped deposition at trial. Judge McCaffrey weighed in on this issue as well in the Roche case, supra, stating: The rules are clear that no deposition may be put to any use except so far as admissible under the rules of evidence. Thus, the Trial Court has broad discretion to prevent the utilization of video deposition as an improper tactic at trial before a jury. Roche at 79. 2) Preparation is key! A good attorney will determine well in advance whether to use a videotaped deposition at trial, which clips to use and how and when to present them. The attorney must be judicious when deciding which video clips to use. He should only present those clips that will provide the most bang for the buck. Thus, it might be wise to leave out a video clip that might only garner a mild reaction from the jury. Overuse is not recommended and may be viewed as theatrical rather then real. The attorney must also consider how he presents the video clip, i.e., the size of the screen, the length of the clip, the use of subtitles, etc. The size of the video screen can influence how a jury views the video. Bigger is not always better. Video clips that are too long may lessen the impact as the jury may lose interest. Including the witness words on the screen could potentially confuse or distract the jury.

5 Lastly, the attorney must consider when to use the video clip. CPLR 3117(b) allows an attorney to use any part of the deposition at trial, however, their adversary may show any other part of the deposition at trial. Thus, a jury may view a video clip on the defense attorney s cross examination of a plaintiff, and the plaintiff s attorney may then present a different video clip on re-direct. Which video clip will the jury remember? The first or the last? Generally, the last thing heard is the first thing remembered. The defense attorney in this instance should find a way to beat his adversary to the punch so that the last video clip the jury sees and remembers is the one he presents. 3) Avoid equipment malfunction! Make sure your video equipment is operating properly. Prepare the video clips you intend to use in advance. Have a separate individual operate the equipment and bring up the clips on cue. There is nothing worse than reaching that point in your questioning where you have locked the witness into an answer that you know is contradicted on the videotaped deposition, and then not being able to upload the video. By the time the problem is fixed, the wow moment is lost and you have lost the jury as well. Conclusion Using videotaped depositions at trial can prove to be extremely beneficial so long as the rules of evidence are followed. In the end, proper and judicious use of a videotaped deposition at trial can bolster any case and lead to a winning verdict.

CONTROLLING STATUTES CPLR Section 3113(b) allows for the taking of depositions via video.

CONTROLLING STATUTES CPLR Section 3113(b) allows for the taking of depositions via video. STATE BAR ASSOCIATION October 27, 2016 Melville, New York BENEFITS AND DETRIMENTS OF VIDEO DEPOSITIONS Andria Simone Kelly, Esq. Ahmuty Demers & McManus 200 I.U. Willets Road Albertson, New York 11507

More information

USE OF DEPOSITIONS. Maryland Rule Deposition Use. (a) When may be used.

USE OF DEPOSITIONS. Maryland Rule Deposition Use. (a) When may be used. USE OF DEPOSITIONS {See P. Niemeyer and L. Schuett, Maryland Rules Commentary, (Third Edition, 2003), pp. 314-319; and P. Grimm, Taking and Defending Depositions: A Handbook for Maryland Lawyers, MICPEL

More information

FRCP 30(b)(6) Notice or subpoena directed to entity to require designation of witness to testify on its behalf.

FRCP 30(b)(6) Notice or subpoena directed to entity to require designation of witness to testify on its behalf. I. Deposition Goals A. Each deposition and each deposition question should be aimed at accomplishing a desired result. 1. Determine knowledge of relevant facts and pin down lack of knowledge of relevant

More information

PART RULES HONORABLE MARIA G. ROSA New York State Supreme Court Dutchess County Supreme Court 10 Market Street Poughkeepsie, New York 12601

PART RULES HONORABLE MARIA G. ROSA New York State Supreme Court Dutchess County Supreme Court 10 Market Street Poughkeepsie, New York 12601 PART RULES HONORABLE MARIA G. ROSA New York State Supreme Court Dutchess County Supreme Court 10 Market Street Poughkeepsie, New York 12601 Phone: 845-431-1752 Fax: 845-486-2227 (1-3-2013 and effective

More information

PREPARING FOR AND TAKING DEPOSITIONS IN A PERSONAL INJURY CASE

PREPARING FOR AND TAKING DEPOSITIONS IN A PERSONAL INJURY CASE PREPARING FOR AND TAKING DEPOSITIONS IN A PERSONAL INJURY CASE Jeffrey K. Anderson, Esq. Anderson, Moschetti & Taffany, PLLC 26 Century Hill Drive, Suite 206 Latham, New York 12110 anderson@amtinjurylaw.com

More information

Do Illinois rules expressly permit video recording of depositions, in lieu of stenography?

Do Illinois rules expressly permit video recording of depositions, in lieu of stenography? Frequently Asked Questions Regarding Remote Video Depositions Under the Illinois Supreme Court Rules on Civil Proceedings in the Trial Court ( Illinois Rules ) Do Illinois rules expressly permit video

More information

COURT RULES OF THE HONORABLE RICHARD MOTT, J.S.C. 401 Union Street Columbia County Courthouse (Temporary)

COURT RULES OF THE HONORABLE RICHARD MOTT, J.S.C. 401 Union Street Columbia County Courthouse (Temporary) REVISED12/12/13 COURT RULES OF THE HONORABLE RICHARD MOTT, J.S.C. Mailing Address: Physical Address: 401 Union Street Columbia County Courthouse (Temporary) Hudson, New York 12534 621 Route 23B Claverack,

More information

THE BASICS OF PHYSICIAN DEPOSITIONS

THE BASICS OF PHYSICIAN DEPOSITIONS THE BASICS OF PHYSICIAN DEPOSITIONS Presented by: www.thehealthlawfirm.com Copyright 2017. George F. Indest III. All rights reserved. George F. Indest III, J.D., M.P.A., LL.M. Board Certified by the Florida

More information

PART TWO VIRGINIA RULES OF EVIDENCE ARTICLE VII. OPINIONS AND EXPERT TESTIMONY.

PART TWO VIRGINIA RULES OF EVIDENCE ARTICLE VII. OPINIONS AND EXPERT TESTIMONY. VIRGINIA: It is ordered that the Rules heretofore adopted and promulgated by this Court and now in effect be and they hereby are amended to become effective July 1, 2013. Amend portions of Part Two, Virginia

More information

FILED: NEW YORK COUNTY CLERK 09/01/ :38 PM INDEX NO /2013 NYSCEF DOC. NO. 352 RECEIVED NYSCEF: 09/01/2017

FILED: NEW YORK COUNTY CLERK 09/01/ :38 PM INDEX NO /2013 NYSCEF DOC. NO. 352 RECEIVED NYSCEF: 09/01/2017 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK SOPHOCLES ZOULLAS, Index No. 155490/2013 vs. Plaintiff, DEFENDANT S PROPOSED JURY CHARGES NICHOLAS ZOULLAS, Defendant. Defendant Nicholas Zoullas

More information

THE SECRET WEAPON: USING THE APPELLATE LAWYER AT TRIAL TO PRIME YOUR CASE FOR APPEAL

THE SECRET WEAPON: USING THE APPELLATE LAWYER AT TRIAL TO PRIME YOUR CASE FOR APPEAL THE SECRET WEAPON: USING THE APPELLATE LAWYER AT TRIAL TO PRIME YOUR CASE FOR APPEAL MICHELLE E. ROBBERSON COOPER & SCULLY, P.C. 900 JACKSON STREET, SUITE 100 DALLAS, TEXAS 75202 OFFICE: (214) 712-9511

More information

FLORIDA RULES OF CIVIL PROCEDURE FOR INVOLUNTARY COMMITMENT OF SEXUALLY VIOLENT PREDATORS

FLORIDA RULES OF CIVIL PROCEDURE FOR INVOLUNTARY COMMITMENT OF SEXUALLY VIOLENT PREDATORS FLORIDA RULES OF CIVIL PROCEDURE FOR INVOLUNTARY COMMITMENT OF SEXUALLY VIOLENT PREDATORS FLORIDA RULES OF CIVIL PROCEDURE FOR INVOLUNTARY COMMITMENT OF SEXUALLY VIOLENT PREDATORS... 1 RULE 4.010. SCOPE

More information

The Tundra Docket: Western District Of Wisconsin

The Tundra Docket: Western District Of Wisconsin Portfolio Media, Inc. 648 Broadway, Suite 200 New York, NY 10012 www.law360.com Phone: +1 212 537 6331 Fax: +1 212 537 6371 customerservice@portfoliomedia.com The Tundra Docket: Western District Of Wisconsin

More information

OUT-OF-STATE DEPOSITIONS, AUDIOVISUAL DEPOSITIONS AND THE USE OF DEPOSITIONS AT TRIAL. PAUL E. WHITE, ESQUIRE Sugarman, Rogers, Barshak & Cohen, P.C.

OUT-OF-STATE DEPOSITIONS, AUDIOVISUAL DEPOSITIONS AND THE USE OF DEPOSITIONS AT TRIAL. PAUL E. WHITE, ESQUIRE Sugarman, Rogers, Barshak & Cohen, P.C. OUT-OF-STATE DEPOSITIONS, AUDIOVISUAL DEPOSITIONS AND THE USE OF DEPOSITIONS AT TRIAL PAUL E. WHITE, ESQUIRE Sugarman, Rogers, Barshak & Cohen, P.C. I. OUT-OF-STATE DEPOSITIONS 1. General Rules Regarding

More information

Masters of the Courtroom SM

Masters of the Courtroom SM Masters of the Courtroom SM Direct & Cross Examination The Hon. Carl J. Barbier, USDC EDLA Darleen M. Jacobs, The Law Offices of Darleen M. Jacobs Kerry Miller, Frilot Course Number: 0200141211 1 Hour

More information

Supreme Court of the State of New York County of Nassau IAS Trial Part 22 Part Rules Updated: January 25, 2018

Supreme Court of the State of New York County of Nassau IAS Trial Part 22 Part Rules Updated: January 25, 2018 Supreme Court of the State of New York County of Nassau IAS Trial Part 22 Part Rules Updated: January 25, 2018 Justice: Law Secretary: Secretary: Part Clerk: Hon. Sharon M.J. Gianelli, J.S.C. Karen L.

More information

Supreme Court of Florida

Supreme Court of Florida Supreme Court of Florida IN RE: AMENDMENTS TO FLORIDA RULES OF CIVIL PROCEDURE No. 93,726 [October 1, 1998] WELLS, J. The Civil Procedure Rules Committee of The Florida Bar has submitted proposed amendments

More information

CONTENTS. vii. Acknowledgments

CONTENTS. vii. Acknowledgments CONTENTS Acknowledgments xvii Chapter 1 The Role and Importance of Depositions 1 The Essentials: Preparation and an Understanding of the Deposition Process 1 How the Book Approaches Depositions 4 The Use

More information

Depositions upon oral examination. A. When depositions may be taken. After commencement of the action, any party may take the testimony of any

Depositions upon oral examination. A. When depositions may be taken. After commencement of the action, any party may take the testimony of any 1-030. Depositions upon oral examination. A. When depositions may be taken. After commencement of the action, any party may take the testimony of any person, including a party, by deposition upon oral

More information

IN THE DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA FOURTH DISTRICT JULY TERM 2004

IN THE DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA FOURTH DISTRICT JULY TERM 2004 IN THE DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA FOURTH DISTRICT JULY TERM 2004 JOSE R. CASTANEDA, a minor, through his natural parent and next friend, ANA CARDONA, and ANA CARDONA, individually,

More information

by Robert J. Permutt, Esq. Assistant General Counsel Lead, Nationwide Insurance Company Mirna M. Santiago, Esq.

by Robert J. Permutt, Esq. Assistant General Counsel Lead, Nationwide Insurance Company Mirna M. Santiago, Esq. by Robert J. Permutt, Esq. Assistant General Counsel Lead, Nationwide Insurance Company Mirna M. Santiago, Esq. Chair Torts, Insurance & Compensation Law Section, New York State Bar Association Of Counsel

More information

WHAT IS A DEPOSITION?

WHAT IS A DEPOSITION? by Robert J. Permutt, Esq. Assistant General Counsel Lead, Nationwide Insurance Company Mirna M. Santiago, Esq. Chair Torts, Insurance & Compensation Law Section, New York State Bar Association Of Counsel

More information

Department 16 has prepared this document to assist counsel in scheduling motions and reporters in Department 16.

Department 16 has prepared this document to assist counsel in scheduling motions and reporters in Department 16. Location: Stanley Mosk Courthouse Department: 16 (213) 633-0516 Motions in Department 16 Department 16 has prepared this document to assist counsel in scheduling motions and reporters in Department 16.

More information

IN THE COURT OF COMMON PLEAS OF LUZERNE COUNTY

IN THE COURT OF COMMON PLEAS OF LUZERNE COUNTY IN THE COURT OF COMMON PLEAS OF LUZERNE COUNTY Plaintiff CIVIL ACTION LAW vs. NO. of Defendant * EACH CASE WILL HAVE ITS OWN UNIQUE TRIAL MANAGEMENT ORDER. SUCH ORDERS WILL TYPICALLY BE IN THIS FORM. TRIAL

More information

ORANGE COUNTY SUPERIOR COURT DEPARTMENT C 10 CIVIL LAW AND MOTION AND TRIAL PROCEDURES JUDGE LINDA S. MARKS

ORANGE COUNTY SUPERIOR COURT DEPARTMENT C 10 CIVIL LAW AND MOTION AND TRIAL PROCEDURES JUDGE LINDA S. MARKS ORANGE COUNTY SUPERIOR COURT DEPARTMENT C 10 CIVIL LAW AND MOTION AND TRIAL PROCEDURES JUDGE LINDA S. MARKS CLERK: CAMILLE TOWNSEND COURT ATTENDANT: KOSAL THACH COURTROOM TEL. NO.: (657) 622-5210 Welcome

More information

Depositions in Oregon

Depositions in Oregon Online CLE Depositions in Oregon 1 Practical Skills or General CLE credit From the Oregon State Bar CLE seminar, presented on June 22, 2017 2017 Joseph Franco. All rights reserved. ii Chapter 3 Depositions

More information

GETTING THE APPELLATE LAWYER INVOLVED EARLY IN LITIGATION

GETTING THE APPELLATE LAWYER INVOLVED EARLY IN LITIGATION GETTING THE APPELLATE LAWYER INVOLVED EARLY IN LITIGATION Michelle E. Robberson COOPER & SCULLY, P.C. 900 Jackson Street, Suite 100 Dallas, Texas 75202 Office: (214) 712-9511 Facsimile: (214) 712-9540

More information

P R E T R I A L O R D E R

P R E T R I A L O R D E R DISTRICT COURT, CITY AND COUNTY OF DENVER COLORADO Address: City and County Building 1437 Bannock Street Denver, CO 80202 COURT USE ONLY Plaintiff(s):, v. Defendant(s):. Case Number: Courtroom: 424 P R

More information

WESTCHESTER COUNTY BAR ASSOCIATION CRIMINAL ASSIGNED COUNSEL PANELS

WESTCHESTER COUNTY BAR ASSOCIATION CRIMINAL ASSIGNED COUNSEL PANELS WESTCHESTER COUNTY BAR ASSOCIATION CRIMINAL ASSIGNED COUNSEL PANELS INFORMATION FOR APPLICANTS Enclosed is the Application for Certification to the Assigned Counsel Panel of the Westchester County Bar

More information

Courtroom Guidelines, Procedures and Expectations for Civil Cases Assigned to Judge Gary L. Sweet Courtroom B Okeechobee County Courthouse

Courtroom Guidelines, Procedures and Expectations for Civil Cases Assigned to Judge Gary L. Sweet Courtroom B Okeechobee County Courthouse Courtroom Guidelines, Procedures and Expectations for Civil Cases Assigned to Judge Gary L. Sweet Courtroom B Okeechobee County Courthouse HEARINGS 1. Special set hearing time (including Foreclosure Summary

More information

IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT OF THE STATE OF FLORIDA IN AND FOR PASCO COUNTY CIVIL DIVISION. Case No. 51-

IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT OF THE STATE OF FLORIDA IN AND FOR PASCO COUNTY CIVIL DIVISION. Case No. 51- IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT OF THE STATE OF FLORIDA IN AND FOR PASCO COUNTY CIVIL DIVISION Case No. 51-, vs. Plaintiff, Defendants. ORDER SETTING JURY TRIAL AND PRE-TRIAL CONFERENCE

More information

The Rules of the Road Approach -- An Examination of a Plaintiff s Strategy for Proving Liability in Trucking Cases

The Rules of the Road Approach -- An Examination of a Plaintiff s Strategy for Proving Liability in Trucking Cases The Rules of the Road Approach -- An Examination of a Plaintiff s Strategy for Proving Liability in Trucking Cases Joseph R. Swift www.brownjames.com Staying abreast of plaintiff lawyers strategies has

More information

STIPULATED PROTECTIVE ORDER

STIPULATED PROTECTIVE ORDER Filed D.C. Sl\p"~rj:)r 10 Apr: ]() P03:07 Clerk ot Court C'j'FI. STEVEN 1. ROSEN Plaintiff SUPERIOR COURT FOR THE DISTRICT OF COLUMBIA CIVIL DIVISION v. Case No.: 09 CA 001256 B Judge Erik P. Christian

More information

REQUESTED ACTION: Approval of an affirmative legislative proposal from the Committee on Civil Practice Law and Rules to amend CPLR 4547.

REQUESTED ACTION: Approval of an affirmative legislative proposal from the Committee on Civil Practice Law and Rules to amend CPLR 4547. Staff Memorandum EXECUTIVE COMMITTEE Agenda Item #15 REQUESTED ACTION: Approval of an affirmative legislative proposal from the Committee on Civil Practice Law and Rules to amend CPLR 4547. Attached is

More information

WESTCHESTER COUNTY BAR ASSOCIATION CRIMINAL ASSIGNED COUNSEL PANELS INFORMATION FOR APPLICANTS

WESTCHESTER COUNTY BAR ASSOCIATION CRIMINAL ASSIGNED COUNSEL PANELS INFORMATION FOR APPLICANTS WESTCHESTER COUNTY BAR ASSOCIATION CRIMINAL ASSIGNED COUNSEL PANELS INFORMATION FOR APPLICANTS Enclosed is the Application for Certification to the Assigned Counsel Panel of the Westchester County Bar

More information

Courtroom Guidelines, Procedures and Expectations for Civil Cases Assigned to Judge Elizabeth A. Metzger Courtroom B, Okeechobee County Courthouse

Courtroom Guidelines, Procedures and Expectations for Civil Cases Assigned to Judge Elizabeth A. Metzger Courtroom B, Okeechobee County Courthouse Courtroom Guidelines, Procedures and Expectations for Civil Cases Assigned to Judge Elizabeth A. Metzger Courtroom B, Okeechobee County Courthouse HEARINGS 1. Special set hearing time: Special set hearing

More information

LOCAL RULES of the COURT OF COMMON PLEAS OF CLARION COUNTY

LOCAL RULES of the COURT OF COMMON PLEAS OF CLARION COUNTY LOCAL RULES of the COURT OF COMMON PLEAS OF CLARION COUNTY Supplementing the Rules of Civil Procedure Promulgated by the Supreme Court of Pennsylvania Effective July 1, 2005 Hon. James G. Arner President

More information

ADVANCED DISCOVERY TECHNIQUES

ADVANCED DISCOVERY TECHNIQUES III. ADVANCED DISCOVERY TECHNIQUES DEPOSITION STRATEGIES A. START EARLY The most important aspect of a successful trial lawyer s practice is thorough preparation. Even the most eloquent and ingenious lawyers

More information

CIVIL DIVISION I PROCEDURES FOR THE THIRTEENTH JUDICIAL CIRCUIT COURT, IN AND FOR HILLSBOROUGH COUNTY, FLORIDA

CIVIL DIVISION I PROCEDURES FOR THE THIRTEENTH JUDICIAL CIRCUIT COURT, IN AND FOR HILLSBOROUGH COUNTY, FLORIDA CIVIL DIVISION I PROCEDURES FOR THE THIRTEENTH JUDICIAL CIRCUIT COURT, IN AND FOR HILLSBOROUGH COUNTY, FLORIDA SECTION 1 PHILOSOPHY, SCOPE AND GOALS 1.1 - Citation to Procedures 1.2 - Purpose and Scope

More information

Video Course Evaluation Form. My Name is: Name of Course: My Street address: Address:

Video Course Evaluation Form. My Name is: Name of Course: My Street address:  Address: Garden State CLE 2000 Hamilton Avenue Hamilton, New Jersey 08619 (609) 584-1924 Phone (609) 584-1920 - Fax Video Course Evaluation Form My Name is: Name of Course: My Street address: City: State: Zip Code:

More information

LEWIS A. KAPLAN United States District Judge United States Courthouse 500 Pearl Street New York, NY 10007

LEWIS A. KAPLAN United States District Judge United States Courthouse 500 Pearl Street New York, NY 10007 LEWIS A. KAPLAN United States District Judge United States Courthouse 500 Pearl Street New York, NY 10007 COMMUNICATIONS For questions concerning general calendar matters, call the Deputy Clerk, Mr. Andrew

More information

Closing Argument Practice Tips

Closing Argument Practice Tips Closing Argument Practice Tips Diane Sullivan Weil, Gotshal & Manges LLP 767 Fifth Avenue New York, NY 10153-0119 17 Hulfish Street, Suite 201 Princeton, NJ 08542 diane.sullivan@weil.com Diane Sullivan

More information

Attorney s BriefCase Beyond the Basics Depositions in Family Law Matters

Attorney s BriefCase Beyond the Basics Depositions in Family Law Matters Attorney s BriefCase Beyond the Basics Depositions in Family Law Matters Code of Civil Procedure 1985.8 Subpoena seeking electronically stored information (a)(1) A subpoena in a civil proceeding may require

More information

Court Rules of The Honorable Martin D. Auffredou, J.S.C. ~ 2017 ~

Court Rules of The Honorable Martin D. Auffredou, J.S.C. ~ 2017 ~ Court Rules of The Honorable Martin D. Auffredou, J.S.C. ~ 2017 ~ Law Clerk: Secretary: Mailing Address: Jill E. O Sullivan, Esq. josulliv@nycourts.gov Shelly Van Nostrand svannost@nycourts.gov Supreme

More information

TAKING AND DEFENDING DEPOSITION September 26, :00-1:00 p.m. Presenter: Thomasina F. Moore, Esq.

TAKING AND DEFENDING DEPOSITION September 26, :00-1:00 p.m. Presenter: Thomasina F. Moore, Esq. TAKING AND DEFENDING DEPOSITION September 26, 2007 12:00-1:00 p.m. Presenter: Thomasina F. Moore, Esq. GENERAL INTRO: IMPORTANCE OF DEPOSITIONS PARTICULARLY IN DEPENDENCY CASES: I. Understanding The Different

More information

The 30.02(6), or 30(b)(6), Witness: Proper Notice, Preparation, and Deposition Techniques

The 30.02(6), or 30(b)(6), Witness: Proper Notice, Preparation, and Deposition Techniques The 30.02(6), or 30(b)(6), Witness: Proper Notice, Preparation, and Deposition Techniques Materials By: James Bryan Moseley Moseley & Moseley, Attorneys At Law 237 Castlewood Drive, Suite D Murfreesboro,

More information

RULES OF SUPREME COURT OF VIRGINIA PART ONE RULES APPLICABLE TO ALL PROCEEDINGS

RULES OF SUPREME COURT OF VIRGINIA PART ONE RULES APPLICABLE TO ALL PROCEEDINGS RULES OF SUPREME COURT OF VIRGINIA PART ONE RULES APPLICABLE TO ALL PROCEEDINGS Rule 1:18. Pretrial Scheduling Order. A. In any civil case the parties, by counsel of record, may agree and submit for approval

More information

P R E T R I A L O R D E R

P R E T R I A L O R D E R DISTRICT COURT, CITY AND COUNTY OF DENVER COLORADO Address: City and County Building 1437 Bannock Street Denver, CO 80202 COURT USE ONLY Plaintiff(s):, v. Defendant(s):. Case Number: Courtroom: 424 P R

More information

Guidelines & Procedures Orange Civil- Division 33

Guidelines & Procedures Orange Civil- Division 33 Guidelines & Procedures Orange Civil- Division 33 Judge Kevin B. Weiss Circuit Judge Jill Gay, Judicial Assistant Phone (407) 836-2354 In Order to assist Counsel, the Litigants and the Court, the following

More information

PREPARING FOR TRIAL. 3. Opponent s experts identified, complete Rule 26 responses received and, if possible and necessary, experts have been deposed.

PREPARING FOR TRIAL. 3. Opponent s experts identified, complete Rule 26 responses received and, if possible and necessary, experts have been deposed. 1 PREPARING FOR TRIAL I. To Be Completed 60 Days Before Trial The following is a list of things that we should endeavor to have done 60 days before trial. While we cannot control what deadlines the court

More information

DEPOSITIONS UPON ORAL EXAMINATION. Notice; Method of Taking; Production at Deposition.

DEPOSITIONS UPON ORAL EXAMINATION. Notice; Method of Taking; Production at Deposition. RULE 1.310. DEPOSITIONS UPON ORAL EXAMINATION (a) When Depositions May Be Taken. After commencement of the action any party may take the testimony of any person, including a party, by deposition upon oral

More information

Work Based Learning & Safety. Work Based Learning & Safety. Work Based Learning & Safety. Do you remember this incident! WORK BASED LEARNING & SAFETY

Work Based Learning & Safety. Work Based Learning & Safety. Work Based Learning & Safety. Do you remember this incident! WORK BASED LEARNING & SAFETY WORK BASED LEARNING & SAFETY IRVING ISD OCTOBER 2011 Presented by Bill Smith New safety hazard found in the workplace! Do you remember this incident! Manchester NHS Trust officials made the decision to

More information

Direct Examination Tips

Direct Examination Tips Direct Examination Tips Lenae Pederson Meagher & Geer PLLP 33 S. Sixth Street #4400 Minneapolis, MN 55402 (612) 371-1334 lpederson@meagher.com Lenae Pederson focuses her practice on complex civil litigation

More information

THERE ARE NO SUBMITTED MOTIONS IN THIS PART AND ALL MOTIONS, WITHOUT EXCEPTION, MUST BE ORALLY ARGUED.

THERE ARE NO SUBMITTED MOTIONS IN THIS PART AND ALL MOTIONS, WITHOUT EXCEPTION, MUST BE ORALLY ARGUED. Supreme Court, Bronx County - Civil Term I.A.S. PART 8 RULES Presiding Justice: Donald A. Miles Courtroom: 706 Chambers: 807 Telephone: (718) 618-1242 Telephone: (718)618-1490 1. APPEARANCES a) Counsel

More information

E-Discovery Best Practices: Admissibility

E-Discovery Best Practices: Admissibility E-Discovery Best Practices: Admissibility Electronic evidence, no matter how probative it may be, is useless if it cannot be used in court. Thus, from the outset of a case, practitioners must pay careful

More information

Thinking Evidentially

Thinking Evidentially Thinking Evidentially Writing & Arguing Powerful Motions October 17, 2013 2013 www.rossdalecle.com Presentation of Proof Plaintiff (or prosecutor) presents case-in-chief, then rests; When witnesses are

More information

P R E T R I A L O R D E R

P R E T R I A L O R D E R DISTRICT COURT, CITY AND COUNTY OF DENVER COLORADO Address: City and County Building 1437 Bannock Street Denver, CO 80202 COURT USE ONLY Plaintiff(s):, v. Defendant(s):. Case Number: Courtroom: 215 P R

More information

Presenting a live 90-minute webinar with interactive Q&A. Today s faculty features: Michael A. Brusca, Shareholder, Stark & Stark, Lawrenceville, N.J.

Presenting a live 90-minute webinar with interactive Q&A. Today s faculty features: Michael A. Brusca, Shareholder, Stark & Stark, Lawrenceville, N.J. Presenting a live 90-minute webinar with interactive Q&A Personal Injury Opening Statements and Closing Arguments: Preparing and Delivering, Handling Objections and Related Motions Developing and Presenting

More information

Frequently Asked Questions Regarding Remote Video Depositions Under the Federal Rules of Civil Procedure

Frequently Asked Questions Regarding Remote Video Depositions Under the Federal Rules of Civil Procedure Frequently Asked Questions Regarding Remote Video Depositions Under the Federal Rules of Civil Procedure Do the federal rules ( FRCP ) expressly permit video recording of depositions, in lieu of stenography?

More information

IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT HILLSBOROUGH COUNTY, FLORIDA GENERAL CIVIL DIVISION

IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT HILLSBOROUGH COUNTY, FLORIDA GENERAL CIVIL DIVISION IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT HILLSBOROUGH COUNTY, FLORIDA GENERAL CIVIL DIVISION Plaintiff(s), CASE NO.: v. DIVISION:. Defendant(s). / UNIFORM ORDER SETTING CAUSE FOR TRIAL AND

More information

TRIAL OBJECTIONS. Considerations Effect on the jury Scrutinous Judiciously Effective/Disruptive

TRIAL OBJECTIONS. Considerations Effect on the jury Scrutinous Judiciously Effective/Disruptive TRIAL OBJECTIONS Albert E. Durkin, Esq. Miroballi Durkin & Rudin LLC Considerations Effect on the jury Scrutinous Judiciously Effective/Disruptive Will the answer hurt your case? Protecting the record

More information

3 of 6 DOCUMENTS. Civil No UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA. 738 F. Supp. 891; 1990 U.S. Dist.

3 of 6 DOCUMENTS. Civil No UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA. 738 F. Supp. 891; 1990 U.S. Dist. Page 1 3 of 6 DOCUMENTS ASSOCIATED PENNSYLVANIA CONSTRUCTORS; SHEET METAL & AIR CONDITIONING CONTRACTORS NATIONAL ASSOCIATION OF PENNSYLVANIA; ASSOCIATED BUILDERS and CONTRACTORS, KEYSTONE CHAPTER; AND

More information

EVIDENCE, FOUNDATIONS AND OBJECTIONS. Laurie Vahey, Esq.

EVIDENCE, FOUNDATIONS AND OBJECTIONS. Laurie Vahey, Esq. EVIDENCE, FOUNDATIONS AND OBJECTIONS Laurie Vahey, Esq. KINDS OF EVIDENCE Testimonial Including depositions Make sure you comply with CPLR requirements Experts Real Documentary Demonstrative Visual aid

More information

Guidelines, Procedures and Expectations Orange County Circuit Civil Division 40 Judge Bob LeBlanc

Guidelines, Procedures and Expectations Orange County Circuit Civil Division 40 Judge Bob LeBlanc Guidelines, Procedures and Expectations Orange County Circuit Civil Division 40 Judge Bob LeBlanc Cindy Brown, Judicial Assistant Phone (407) 836 2012 Email ctjacb1@ocnjcc.org **NOTE: REVISED AND EFFECTIVE

More information

Depositions: Practice Pointers

Depositions: Practice Pointers Depositions: Practice Pointers Virginia Trial Lawyers Association Annual Tort Law Seminar May 10, 2017 By Roger T. Creager 1 The Creager Law Firm, PLLC 1500 Forest Avenue, Suite 120 Richmond, Virginia

More information

Part I Preparing Yourself for Trial

Part I Preparing Yourself for Trial Part I Preparing Yourself for Trial By: Patrick J. Higgins Couch White, LLP 540 Broadway Albany, NY 12207 (518) 426 4600 The Trial Mindset This is law school Your control of process and outcome This is

More information

MINNESOTA JUDICIAL TRAINING UPDATE

MINNESOTA JUDICIAL TRAINING UPDATE MINNESOTA JUDICIAL TRAINING UPDATE CAUTIONARY JURY INSTRUCTIONS DURING TRIAL Problem: You re In The Middle Of Trial And Something Occurs (Usually An Evidentiary Issue) That Requires A Cautionary Instruction

More information

Legnetti v Camp America 2011 NY Slip Op 33754(U) December 21, 2011 Sup Ct, Nassau County Docket Number: 1113/09 Judge: Antonio I.

Legnetti v Camp America 2011 NY Slip Op 33754(U) December 21, 2011 Sup Ct, Nassau County Docket Number: 1113/09 Judge: Antonio I. Legnetti v Camp America 2011 NY Slip Op 33754(U) December 21, 2011 Sup Ct, Nassau County Docket Number: 1113/09 Judge: Antonio I. Brandveen Cases posted with a "30000" identifier, i.e., 2013 NY Slip Op

More information

CIVIL PRETRIAL PRACTICE SPRING 2006 SYLLABUS

CIVIL PRETRIAL PRACTICE SPRING 2006 SYLLABUS CIVIL PRETRIAL PRACTICE SPRING 2006 SYLLABUS Week 1: January 12 Lecture: Introduction to the Course, Factual and Legal Context for the Simulated Case, and Litigation Planning. Assignment: Review accident

More information

INDIVIDUAL RULES AND PROCEDURES FOR CIVIL CASES. Lorna G. Schofield United States District Judge

INDIVIDUAL RULES AND PROCEDURES FOR CIVIL CASES. Lorna G. Schofield United States District Judge INDIVIDUAL RULES AND PROCEDURES FOR CIVIL CASES Lorna G. Schofield United States District Judge Mailing Address: United States District Court Southern District of New York 500 Pearl Street New York, New

More information

PART III Discovery CHAPTER 8. Overview of the Discovery Process KEY POINTS THE NATURE OF DISCOVERY THE EXTENT OF ALLOWABLE DISCOVERY

PART III Discovery CHAPTER 8. Overview of the Discovery Process KEY POINTS THE NATURE OF DISCOVERY THE EXTENT OF ALLOWABLE DISCOVERY PART III Discovery CHAPTER 8 Overview of the Discovery Process The Florida Rules of Civil Procedure regulate civil discovery procedures in the state. Florida does not require supplementary responses to

More information

QUESTIONNAIRE FOR JUDGE/COMMISSIONER BENCH BOOK. JUDGE/COMMISSIONER: Jennifer Valencia Second District Court

QUESTIONNAIRE FOR JUDGE/COMMISSIONER BENCH BOOK. JUDGE/COMMISSIONER: Jennifer Valencia Second District Court 1. Discovery QUESTIONNAIRE FOR JUDGE/COMMISSIONER BENCH BOOK JUDGE/COMMISSIONER: Jennifer Valencia Second District Court Q: What is your practice with respect to setting an initial case schedule? Modifying

More information

CBA Municipal Court Pro Bono Panel Program Municipal Procedure Guide 1 February 2011

CBA Municipal Court Pro Bono Panel Program Municipal Procedure Guide 1 February 2011 CBA Municipal Court Pro Bono Panel Program Municipal Procedure Guide 1 February 2011 I. Initial steps A. CARPLS Screening. Every new case is screened by CARPLS at the Municipal Court Advice Desk. Located

More information

9 of their attorneys you have learned the conclusion which 10 each party believes should be drawn from the evidence

9 of their attorneys you have learned the conclusion which 10 each party believes should be drawn from the evidence 6 THE COURT: Thank you very much, Mr. Kelly. 7 Members of the jury, you have now heard all the 8 evidence Introduced by the parties and through the arguments 9 of their attorneys you have learned the conclusion

More information

GENERAL CLOSING INSTRUCTIONS. Members of the jury, it is now time for me to tell you the law that applies to

GENERAL CLOSING INSTRUCTIONS. Members of the jury, it is now time for me to tell you the law that applies to GENERAL CLOSING INSTRUCTIONS Members of the jury, it is now time for me to tell you the law that applies to this case. As I mentioned at the beginning of the trial, you must follow the law as I state it

More information

PRE-TRIAL PROCEDURES & PROTOCOL FOR JURY TRIALS & REFERRAL TO MEDIATION Revised March 2, 2018 (to correct web link only)

PRE-TRIAL PROCEDURES & PROTOCOL FOR JURY TRIALS & REFERRAL TO MEDIATION Revised March 2, 2018 (to correct web link only) CIRCUIT CIVIL SARASOTA COUNTY PRE-TRIAL PROCEDURES & PROTOCOL FOR JURY TRIALS & REFERRAL TO MEDIATION Revised March 2, 2018 (to correct web link only) I LOCAL RULES, STANDARDS OF PROFESSIONALISM & GOOD

More information

Streamlined Arbitration Rules and Procedures

Streamlined Arbitration Rules and Procedures RESOLUTIONS, LLC s GUIDE TO DISPUTE RESOLUTION Streamlined Arbitration Rules and Procedures 1. Scope of Rules The RESOLUTIONS, LLC Streamlined Arbitration Rules and Procedures ("Rules") govern binding

More information

DIRECT EXAMINATION. Robert E. Harrington Robinson, Bradshaw & Hinson, P.A.

DIRECT EXAMINATION. Robert E. Harrington Robinson, Bradshaw & Hinson, P.A. DIRECT EXAMINATION Robert E. Harrington Robinson, Bradshaw & Hinson, P.A. John S. Leary Association of Black Lawyers Trial Advocacy CLE September 17, 2011 DIRECT EXAMINATION UNDERSTAND THE ROLE AND IMPORTANCE

More information

INSTRUCTIONS AFTER JURY IS SWORN

INSTRUCTIONS AFTER JURY IS SWORN Revised 10/15/12 INSTRUCTIONS AFTER JURY IS SWORN Ladies and Gentlemen of the jury, you have been selected as the jury in this case. As you know this is a criminal case, and to assist you in better understanding

More information

4. CROSS EXAMINATION 159

4. CROSS EXAMINATION 159 4. CROSS EXAMINATION 159 160 Trial Advocacy, Cross-Examination: The Basics Ben B. Rubinowitz and Evan Torgan Cross-examination involves relatively straightforward skills. Through preparation of your case,

More information

11.00 MANDATORY ARBITRATION PROCEEDINGS GOVERNED BY ILLINOIS SUPREME COURT RULES

11.00 MANDATORY ARBITRATION PROCEEDINGS GOVERNED BY ILLINOIS SUPREME COURT RULES ARTICLE 11: MANDATORY ARBITRATION 11.00 MANDATORY ARBITRATION PROCEEDINGS GOVERNED BY ILLINOIS SUPREME COURT RULES (a) The Mandatory Arbitration Program in the Circuit Court for the Sixteenth Judicial

More information

Case: 2:06-cv ALM-TPK Doc #: 580 Filed: 03/08/16 Page: 1 of 27 PAGEID #: 17549

Case: 2:06-cv ALM-TPK Doc #: 580 Filed: 03/08/16 Page: 1 of 27 PAGEID #: 17549 Case: 2:06-cv-00896-ALM-TPK Doc #: 580 Filed: 03/08/16 Page: 1 of 27 PAGEID #: 17549 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO EASTERN DIVISION THE NORTHEAST OHIO COALITION

More information

Dynamic Opening Statements How to Establish Credibility and Persuade From the Beginning

Dynamic Opening Statements How to Establish Credibility and Persuade From the Beginning Dynamic Opening Statements How to Establish Credibility and Persuade From the Beginning Christopher D. Glover Beasley, Allen, Crow, Methvin, Portis & Miles, P.C. Persuade From the Beginning Never Underestimate

More information

QUESTIONNAIRE FOR JUDGE/COMMISSIONER BENCH BOOK. Judge Andrew Stone Third District Court QUESTIONS :

QUESTIONNAIRE FOR JUDGE/COMMISSIONER BENCH BOOK. Judge Andrew Stone Third District Court QUESTIONS : 1. Discovery QUESTIONNAIRE FOR JUDGE/COMMISSIONER BENCH BOOK Judge Andrew Stone Third District Court QUESTIONS : 3rdStoneteam@utcourts.gov Q: What is your practice with respect to setting an initial case

More information

JUDGE GABRIELLE N. SANDERS Courtroom Guidelines, Procedures and Expectations For Osceola County Civil Division 60-G, Courtroom 4B

JUDGE GABRIELLE N. SANDERS Courtroom Guidelines, Procedures and Expectations For Osceola County Civil Division 60-G, Courtroom 4B STATE OF FLORIDA NINTH JUDICIAL CIRCUIT OF FLORIDA COUNTIES OF ORANGE AND OSCEOLA OSCEOLA COUNTY COURTHOUSE 2 COURTHOUSE SQUARE, SUITE 6425 KISSIMMEE, FLORIDA 34741 (407) 742-2495 WWW.NINTHCIRCUIT.ORG

More information

INDIVIDUAL PRACTICES IN CIVIL CASES Nelson S. Román, United States District Judge. Courtroom Deputy Clerk

INDIVIDUAL PRACTICES IN CIVIL CASES Nelson S. Román, United States District Judge. Courtroom Deputy Clerk July 23, 2013 INDIVIDUAL PRACTICES IN CIVIL CASES Nelson S. Román, United States District Judge Chambers Courtroom Deputy Clerk United States Courthouse Ms. Gina Sicora 300 Quarropas Street (914) 390-4178

More information

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF MISSOURI WESTERN DIVISION GOVERNMENT'S PROPOSED JURY INSTRUCTIONS

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF MISSOURI WESTERN DIVISION GOVERNMENT'S PROPOSED JURY INSTRUCTIONS IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF MISSOURI WESTERN DIVISION UNITED STATES OF AMERICA, Plaintiff, v. Case No. 12-00075-01-CR-W-DW MARCUS D. GAMMAGE, Defendant. GOVERNMENT'S

More information

TRIAL ADVOCACY - FALL 2005

TRIAL ADVOCACY - FALL 2005 TRIAL ADVOCACY - FALL 2005 Thomas K. Maher 312 W Franklin Street Chapel Hill, N.C. 27516 (O) 929-1043 (H) 933-5674 TKMaher@tkmaherlaw.com General Instructions 1. General Information. The class will meet

More information

SUPREME COURT - NASSAU COUNTY IAS PART 14 PART MATRIMONIAL RULES & PROCEDURES (revised 05/23/17)

SUPREME COURT - NASSAU COUNTY IAS PART 14 PART MATRIMONIAL RULES & PROCEDURES (revised 05/23/17) SUPREME COURT - NASSAU COUNTY IAS PART 14 PART MATRIMONIAL RULES & PROCEDURES (revised 05/23/17) Justice: Law Clerk: Secretary: Part Clerk: HON. ROBERT A. BRUNO RACHEL ZAMPINO, ESQ. CORINNE GLANZMAN BILL

More information

IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COUNTY DEPARTMENT CHANCERY DIVISION CALENDAR 7 COURTROOM 2405 JUDGE DIANE J. LARSEN STANDING ORDER 2.

IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COUNTY DEPARTMENT CHANCERY DIVISION CALENDAR 7 COURTROOM 2405 JUDGE DIANE J. LARSEN STANDING ORDER 2. IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COUNTY DEPARTMENT CHANCERY DIVISION Chambers Telephone: 312-603-3343 Courtroom Clerk: Phil Amato Law Clerks: Azar Alexander & Andrew Sarros CALENDAR 7 COURTROOM

More information

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA Case 2:4-cv-00-AB-E Document Filed 02// Page of Page ID #:04 2 3 4 0 2 3 4 LORRAINE FLORES, et al. v. UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA Plaintiffs, SWIFT TRANSPORTATION COMPANY,

More information

NC General Statutes - Chapter 1A Article 5 1

NC General Statutes - Chapter 1A Article 5 1 Article 5. Depositions and Discovery. Rule 26. General provisions governing discovery. (a) Discovery methods. Parties may obtain discovery by one or more of the following methods: depositions upon oral

More information

COMMERCIAL DIVISION PRELIMINARY CONFERENCE ORDER PURSUANT TO PART 202 OF THE UNIFORM CIVIL RULES FOR THE SUPREME COURT KINGS COUNTY

COMMERCIAL DIVISION PRELIMINARY CONFERENCE ORDER PURSUANT TO PART 202 OF THE UNIFORM CIVIL RULES FOR THE SUPREME COURT KINGS COUNTY COMMERCIAL DIVISION PRELIMINARY CONFERENCE ORDER PURSUANT TO PART 202 OF THE UNIFORM CIVIL RULES FOR THE SUPREME COURT KINGS COUNTY DATE 200 Plaintiff(s) -against- Index # Defendant(s) Plaintiff is represented

More information

COMPLEX BUSINESS LITIGATION DIVISION PROCEDURES FOR THE THIRTEENTH JUDICIAL CIRCUIT COURT, IN AND FOR HILLSBOROUGH COUNTY, FLORIDA

COMPLEX BUSINESS LITIGATION DIVISION PROCEDURES FOR THE THIRTEENTH JUDICIAL CIRCUIT COURT, IN AND FOR HILLSBOROUGH COUNTY, FLORIDA COMPLEX BUSINESS LITIGATION DIVISION PROCEDURES FOR THE THIRTEENTH JUDICIAL CIRCUIT COURT, IN AND FOR HILLSBOROUGH COUNTY, FLORIDA SECTION 1 PHILOSOPHY, SCOPE AND GOALS 1.1 - Citation to Procedure 1.2

More information

An Overview of Civil Litigation in the U.S. presented by Martijn Steger May 24, 2014

An Overview of Civil Litigation in the U.S. presented by Martijn Steger May 24, 2014 presented by Martijn Steger May 24, 2014 General Explanation of Civil Litigation in the U.S. U.S. litigation is governed by + + Rules of Civil Procedure; and + + Rules of Evidence. Rules of Civil Procedure:

More information

Table of Contents. Relevant Rules... 4 Contact Us Transitional reporting period examples... 3

Table of Contents. Relevant Rules... 4 Contact Us Transitional reporting period examples... 3 Guide to Transitional Year-End Reporting July 2017 Table of Contents Introduction... 1 Definitions... 1 Trust Safety Rule Amendments... 2 Transitional Reporting Period... 2 Transitional Reporting Period

More information

CALIFORNIA RULES OF COURT Title 3. Civil Rules Division 8. Alternative Dispute Resolution Chapter 1. General Provisions

CALIFORNIA RULES OF COURT Title 3. Civil Rules Division 8. Alternative Dispute Resolution Chapter 1. General Provisions Page 1 Chapter 1. General Provisions Cal Rules of Court, Rule 3.800 (2009) Rule 3.800. Definitions As used in this division: (1) "Alternative dispute resolution process" or "ADR process" means a process,

More information

Division 58 Procedures Fla. R. Jud. Admin (b) requires the trial judge take charge of all cases at an early stage in the litigation and shall

Division 58 Procedures Fla. R. Jud. Admin (b) requires the trial judge take charge of all cases at an early stage in the litigation and shall Division 58 Procedures Fla. R. Jud. Admin. 2.545(b) requires the trial judge take charge of all cases at an early stage in the litigation and shall control the progress of the case thereafter until the

More information

SWGDOG SC 6 PRESENTATION OF EVIDENCE IN COURT

SWGDOG SC 6 PRESENTATION OF EVIDENCE IN COURT SWGDOG SC 6 PRESENTATION OF EVIDENCE IN COURT Posted for public comment 7/10/06 9/10/06. Approved by membership 10/2/06. 1 st Revision - Posted for Public Comment 5/24/10 7/22/10. Approved by membership

More information

Deposition Do s and Don ts 1 hour

Deposition Do s and Don ts 1 hour Deposition Do s and Don ts 1 hour Copyright 2016 by Comedian of Law LLC All rights reserved. Printed in the United States of America. Written permission must be secured from the publisher to use or reproduce

More information