- Revision 7
- 60 custom-drafted forms
- Access to digital forms on Jamesforms.com
- ISBN: 1-58012-114-4
Deposition Checklists & Strategies
Hundreds of pattern questions for treating physicians, corporate representatives, insurers, lay witnesses, defendants, and others. Annotated with strategic suggestions, pitfalls to avoid, and bonus discovery forms.
by Evan Schaeffer
- Revision 7
1,000’s of deposition questions are supported with strategy, law, practice tips, and thumbnail deposition outlines. Troublesome answers are annotated with commentary and follow-up questions. Covers auto accidents, premises liability, products liability, medical malpractice, employment discrimination and termination, and insurance coverage disputes.
Fast and Thorough Deposition Preparation
Creating an outline is the most efficient way of formalizing your preparation for a deposition.
Use the outlines and pattern questions in Deposition Checklists & Strategies to avoid omissions, improve your advocacy, and handle unfamiliar areas with confidence. You receive:
- Underlying law. Each chapter begins with a summary of the substantive law at issue. Also included is an analysis of common defenses.
- Deposition outlines. Each chapter contains several full-length deposition Q&A sections organized by issue, based on common fact patterns, and directed at specialized deponents like experts, corporate representatives, and treating physicians. The book’s questions are easy to mix and match with your own.
- Commentary. Thorny or common issues are annotated with practice-proven alternatives and solutions.
- Bonus outlines. Thumbnail checklists that contain themes and issues rather than question-and answer dialogue are provided for less-common deponents.
- Related discovery forms. Complaints, interrogatories, requests for admissions, requests to produce, and more finish each chapter.
- Practice tips. Sprinkled through each pattern deposition is practical advice learned from hundreds of depositions.
Each pattern deposition outline contains extensive questions and selected answers for the issues most likely to arise. Troublesome answers are annotated with commentary and follow-up questions. Here is an example of the subjects covered in one sample deposition:
Defendant Driver in Auto Case
- Thumbnail Outline with Issues and Themes
- Preliminary Questions
Witness’ Preparation for the Deposition
Witness’s Relationship to Other Parties and Witnesses
- The Collision
Events Leading Up to the Collision
After the Collision
Driving Experience and Licensure
- Defendant’s Condition on Day of Collision
Defendant’s Activities on the Day of the Collision
Estimates of Times
Alcohol and Drugs
- The Vehicles
Condition of the Deponent’s Vehicle Before the Collision
Condition of the Vehicles After the Collision
Lack of Damage as Evidence of Negligible Force
- Traffic Tickets and Plaintiff’s Negligence
Plaintiff’s Contributory Negligence
- Admissions, Witnesses, and Statements
All Witnesses to the Occurrence
Knowledge of Conversations
Informal Statements and Interviews
Conversations About the Accident or the Lawsuit
Photographs and Diagrams
Chapter 1: Deposition Procedures and Strategies
Chapter 2: Vehicular Liability
Chapter 3: Premises Liability
Chapter 4: Products Liability
Chapter 5: Medical Malpractice
Chapter 6: Employment Discrimination and Termination
Chapter 7: Insurance Coverage Disputes
Chapter 8: Consumer Protection and Deceptive Trade Practices
Chapter 9: Breach of Contract
T. Evan Schaeffer is a 1990 magna cum laude graduate of St. Louis University School of Law, where he was the Managing Editor of the St. Louis University Law Journal and received American Jurisprudence Awards in Contracts, Property and Evidence. Mr. Schaeffer is a member of Phi Beta Kappa and the Order of the Woolsack.
Mr. Schaeffer was admitted to the Missouri and Illinois bars in 1990. He began his career as a defense lawyer, but since 1996 has worked primarily on the plaintiffs’ side. Schaeffer’s areas of practice include complex commercial and tort litigation, including mass torts and class actions, as well as general civil litigation. He is a principal of Schaeffer & Lamere, P.C., based in the metropolitan St. Louis area.
Mr. Schaeffer’s publications include articles and essays in many newspapers and magazines, including the Chicago Tribune, the Houston Chronicle, the St. Louis Post-Dispatch, and the Illinois Bar Journal. Mr. Schaeffer also publishes two weblogs, The Trial Practice Tips Weblog and Evan Schaeffer’s Legal Underground, which together have received notice in many print publications, including the New York Times and The Economist.
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