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July 10, 2012

What a great 1st chair does 60 days before a civil trial.

Quick, dirty, fun and well worth the time and effort. If you will be lead counsel in your next jury trial, this suggestion: no more than 60 days from trial, read over and take a proverbial bath in all of the written discovery responses and--if time permits--every deposition transcript in the case. Work through the materials relatively quickly but as thoroughly as you can. In particular, do one good read of any deposition you did not take yourself. And of all written and signed discovery responses (you can skip the documents). Go back to the start of the case. Do not rely only on deposition summaries or on outlines of direct or cross examinations prepared by others. The process of "immersing yourself" in all the discovery will suggest new sub-themes, patterns, weak points and even a new fact or two in your opponent's case that meant little to your side when it was first produced. Now discovery will take on new and instructive meanings. Having gone through that exercise, you will be steeped in the case. You'll have knowledge that will give your examinations of witnesses credibility, authority and command. Try it.

Edward Bennett Williams

Posted by JD Hull at July 10, 2012 12:03 AM


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