The Discovery Update – February 2011


The Discovery Update – February 2011

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February 2011

From the President

Because we know that the success of your depositions is of the utmost importance to you and your clients, we continue to focus on providing you with useful tips, tools and information in our e-newsletters.

To this effect, this month we have included an article which outlines the benefits of using an iPad as a legal tool and helpful information on how to work with an interpreter for your depositions.

As always, we invite you to send us any articles or tips you may have regarding the discovery process, so we can share them with our readers.

Best regards,
Sheila Atkinson-Baker


Why Preparing Clients for Deposition is Like Making Pancakes

By Brian Wilson, Nicodemo & Wilson

What is the one HUGE secret for making fluffy pancakes that rise like they should, as opposed to those paper thin, dense duds devoid of any texture or sponginess? And, by the way, as a long time weekend pancake slinger, this secret applies to homemade recipes (my usual choice) all the way down to the instant “just add water” mixes.

The secret? Don’t overwork the batter and DO NOT stir the lumps out of the mix. Simply add enough liquid (per whatever directions you’re following) to dissolve the dry batter and gently fold the liquid in. Within a few seconds, you’ll have enough consistency to be able to spoon or ladle a lump-filled blob of batter onto your griddle or into your pan. And then watch them slowly puff up and rise, in airy-like, glorious fashion.

Not too long ago, I came to the conclusion that preparing our clients for deposition is a lot like making pancakes. We hit clients with all these pre-deposition rules like “don’t guess,” “don’t ramble,” “answer only the question you’re asked and don’t volunteer anything,” etc. I could go on and cite about 15 more “rules” we’ve all learned over the years and have bludgeoned our clients with from time to time.
Read full article >>

Why Preparing Clients for Deposition is Like Making Pancakes

Risk of Rewards

Stamp File Names on PDFs with This Free Acrobat X Action

Evidence: Lawyer Proof and Juror Proof


Case Law Relevant to Electronic Discovery »

The Court Reporter’s Brain: “A Miracle” »


Risk of Rewards
Read article »
Stamp File Names on PDFs with This Free Acrobat X Action
Evidence: Lawyer Proof and Juror Proof



Student 1: “Where were you?”
Student 2: “I was working on a guy’s D&D case. (drinking and driving)”
Student 1: “Dungeons and Dragons?”
Student 2: “Yes. A Paladin battered an Elf and stole his Sword of a Thousand Truths.”


Attorney: How would you characterize your departure from the restaurant?
Witness: I quit.
Attorney: Under what circumstances?
Witness: I found out he had replaced me.