Episode 23 - Cross-Notice Jiu Jitsu: Using An Opponent's Cross-Notice Against It

It's not unusual for adversaries to cross-notice your key depositions, either of their own witnesses or of non-party deponents. That allows them unfettered ability to conduct a wide-open, more focused followup examination (after listening to yours). In this episode, Jim Garrity shares a tactic for flipping the script on your opponents, forcing them to go first, and allowing you to sit back and learn what the lawyer and deponent really know before it's your turn.