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March 26, 2020

Make Mine Moxie.

Sometimes you have to look reality in the eye and deny it.

--Garrison Keillor

Posted by JD Hull at 11:59 PM | Comments (0)

March 20, 2020

Equinox

Posted by JD Hull at 01:08 PM | Comments (0)

March 18, 2020

Bravado

I believe in God, Planning, Work and and Human Bravado. Don’t listen to woke culture pundits on the utility of Bravado. Bravado is primal. We’re wired for it. Men and Women. Even children. It worked for Beowulf, Odysseus and Ted Turner. It can work for you. And it’s Fun.

Posted by JD Hull at 11:05 PM | Comments (0)

March 12, 2020

Happy Birthday Jean-Louis Kérouac (March 12, 1922 - October 21, 1969)

Jack Kerouac in Lowell-Lawrence game, 1938. Photo: Lowell Sun

Posted by JD Hull at 11:15 PM | Comments (0)

March 11, 2020

J. Daniel Hull, Jr. (March 11, 1900 - October 13, 1987)

Happy birthday, Grandpop. I still miss you.

Posted by JD Hull at 07:15 PM | Comments (0)

March 05, 2020

Sensitive Litigation Moment: Depositions and FRE 612.

FRE 612 provides that if a witness uses a writing "to refresh memory", either while or before testifying, the adverse party is "entitled to have the writing produced at the hearing, to inspect it, to cross-examine the witness" on the document. Good trial lawyers overlook that FRE 612 applies to depositions as well as to trials. Federal decisions have applied the rule to depositions based upon Fed.R.Civ.P. 30(c). So ask a deponent if he or she looked at documents before the deposition other than those being produced at the deposition. If the answer is "yes", request that they be produced. Go to the judge. You can have them produced during or after the deposition. Often the best documents are the ones that never make it to the deposition, like handwritten records that even opposing counsel doesn't know about.

Scopes trial, outdoor proceedings, July 20, 1925

Posted by JD Hull at 11:10 AM | Comments (0)

March 02, 2020

Happy 184th, Republic of Texas

Texas Declaration of Independence, March 2, 1836

Posted by JD Hull at 09:15 AM | Comments (0)