10,000 Depositions Later: The Premier Litigation Guide for Superior Deposition Practice

From Jim Garrity, the country’s leading deposition expert, comes this greatly expanded Third Edition on world-class deposition strategies and tactics. At almost 500 pages, it is jam-packed with immediately useful advice and guidance. Garrity has appeared as lead trial counsel in more than two thousand federal and state civil cases. His personal deposition experience now far exceeds the 10,000 mentioned in the title. (For business reasons, his publisher did not want him to update the title number.) He’s been up against the best litigators at hundreds of firms, from the nation’s largest to sole practitioners, and there’s literally no tactic, trick, variation or strategy he hasn’t seen hundreds of times. Indeed, one federal judge, commenting in open court, observed that Garrity “has pulled multiple rabbits out of multiple hats,” meaning he wins cases against inconceivable odds. How? Because of his extraordinary deposition skills. Depositions are the decisive factor in nearly all settlements and trials. You cannot achieve excellent outcomes if you cannot prevail in your depositions.So you need a deposition mentor with unparalleled experience. But how to choose? Here’s how. First ask, does the author practice in an extremely deposition-intensive field? Second, does the author have long-term, high-volume, provable experience? The federal PACER database allows you to enter lawyer names in the party field. Third, is the book based on the author’s first-hand experience? Or is it a second-hand retelling of others’ cases? This Third Edition contains fourteen highly-detailed chapters, with more than 275 sub-topics. It is a litigator’s dream field manual, not only revealing cutting-edge techniques and procedures but telling you how to combine them creatively and successfully. Learn how to gain advantage at every step. Learn the path to victory and learn where the landmines are along that path. Discover the legitimate (and illegitimate) tactics opponents use that you’ve never seen before. The book is heavy on insights you can immediately implement. Regardless of your years of experience, the book will provide an astonishing advantage. And the book contains heavy citation to court decisions to support Garrity’s advice. His expert guidance begins with the moment you first conceive plans to capture testimony – whether by deposition, affidavit or EUO (and he’ll tell you which to use and when). Most importantly, in each section, he explains what he does and why. No part of the deposition process is overlooked – forming the battle plan, scheduling, dealing with reporters, taking depositions, defending them, prepping witnesses to make them invincible, handling every conceivable type of witness, making objections, dealing with obstructive lawyers, and tips pertinent to deposition transcripts, from the moment of receipt through trial. Some additional examples of the valuable insights you’ll learn: A technique for prepping witnesses to forcefully overcome an examiner’s suggestion that knowledge gained circumstantially is “speculation” and isn’t something your witness “knows”; why you should routinely audiotape depositions, apart from the reporter; why you should agree to “the usual stipulations” with great caution; and dozens and dozens of novel tips for both taking and defending. Top-tier active practitioners rarely share their best tips. But Jim Garrity has done exactly that, and you’ll find them all right here.