Deposition Skills
To hone up on your deposition skills I highly recommend the DVD (it also comes in CD) entiled "Deposition Techniques: Strategies, Tactics and Skills" by David Markowitz. You can order the DVD here.
FRCP 30(b)(6)
If you are taking or defending a 30(b)(6) deposition remember that there are two different sets of court opinions on the scope of a 30(b)(6) deposition. The majority opinion is that the questioner can ask any question permitted by FRCP 26. The minority opinion is that the questioner can only ask questions relating to the specific areas that were designated in the notice for the 30(b)(6) deposition. So before taking or defending a 30(b)(6) deposition take the time to find out whether your federal circuit or your state courts follow the majority or minority opinion. If your jurisdiction follows the minority rule your best option, if you are noting the deposition, is to set forth in your notice the areas upon which you expect the witness to be prepared to answer in the broadest terms possible.
PDFs
If you want to learn about Adobe Acrobat and how lawyers put it to use go to Ernie Svenson's blog: "PDF for Lawyers - Smart tips for busy lawyers and legal professionals". This is one blog where I find myself going through not only the recent posts but also the archived posts. There is plenty to learn from this blog.
One Question
The next time you are preparing for a deposition think of the one question you would ask the deponent if you only had one question to ask. This should help you focus on what it is that you want out of the deponent. Also, you might find out if you actually start asking that one question at your depositions that your depositions will be much more productive and efficient.
Watch your language
I happened to run across an old posting at Litigation & Trial. The post is labeled "How To Write Your Brief So That The Judge Will Hate You" and can be found here. I think it is well worth reading. It seems to me that the language (sarcasm and sniping at the opponents) found in the brief that is quoted in the article is all too common. My first thought was that the next time I see such language in an opposing brief I would find a way to point it out to the judge, but on second thought it seems that one can "point it out" simply by not doing it your own brief and the stark contrast should say all that is needed.
