Episode 42 - Lessons from the Front Lines - Carefully Choose the Documents You Use to Prepare Deponents

In this Lessons from the Front Lines episode, where we review brand-new deposition-related cases from around the country, Jim Garrity discusses two decisions that highlight the importance of - and risks associated with - choosing the documents you used to prepare deponents, especially unrepresented non-party witnesses. Garrity shares key insights, and offers practical tips at the end of the episode. The cases upon which this episode is based are cited in the show notes.SHOW NOTES:Rodolfo Tecocoatzi-Ortiz, et al. v. Just Salad LLC, 2021 WL 2011913, Case No.: 18-CV-7342-JGK-BCM (S.D.N.Y. May 19, 2021) (judge orders lawyer to produce, for in camera inspection, documents used to prepare his client for deposition, after defense counsel sought court assistance in compelling production)Johnson v. Baltimore Police Department, et al., 2021 WL 1985014, Case No. ELH-19-698 (D. Maryland May 18, 2021) (lawyer ordered to produce documents used to prepare non-party witness for deposition)