Episode 178: How to Revoke Invocation of the Fifth Amendment Privilege After a Deposition
You know how to assert a Fifth Amendment privilege in a deposition. But how to withdraw it, once the threat of criminal prosecution is gone?...
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10,000 Depositions Later Podcast
From Jim Garrity, the country’s leading deposition expert, comes this podcast for hardcore litigators. The subject? Taking and defending depositions.Each episode is a one-topic, mini field g...
Episodes
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Episode 177 - Lessons from the Front Lines: Touhy or Not Touhy? The Difficulties of Deposing Federal Employees
In this episode, Jim Garrity explains the procedure for deposing current or former federal government employees where the federal government...
Episode 176 - You Don't Have to Prepay Experts Before Their Deposition
How many times have you noticed an expert witness for deposition, only to be told you've got to pay their fee in advance, failing which, the...
Episode 175: Lessons from the Front Lines: "We Outsourced It" - Countering the 30(b)(6) Ignorance Defense
What to do when an organization resists your efforts to conduct a Fed. R. Civ. P. 30(b)(6) deposition by claiming it not only doesn't curren...
Episode 174 - Lessons From The Front Lines: In-Person Depos are the Default Again (And a Psychological Reason for Insisting On Them)
In this episode, we feature a brand-new deposition-related ruling that continues to build on the post-COVID pandemic rulings holding that in...
Episode 173 - Improper Preliminary Instructions or "Ground Rules"
Have you ever had a queasy feeling, as an examining lawyer is explaining the so-called ground rules for the deposition with your witness, th...
Episode 172: Second-Order Knowledge Examinations
In this episode, Jim talks about the value of "second-order" examinations - asking deponents not only what they know, but what others know (...
Episode 171: Examination Techniques, Part 4 - The Reid Technique
In this final episode of our cross-examination series, Jim Garrity turns to the Reid Technique, the interrogation system developed in the 19...
Episode 170 - Examination Techniques: The Reptile Method
In this third installment of our series on examination techniques, Jim Garrity dives into the so-called Reptile Method, developed by jury co...
Episode 169: Examination Techniques: Irving Younger's Ten Commandments of Cross-Examination
In this second episode in a series on different cross-examination methods, Jim Garrity spotlights Irving Younger's famed Ten Commandments of...
Episode 168: Examination Techniques: The Pozner-Dodd Technique
In this episode, and over the next few, Jim Garrity analyzes some of the better-known techniques or methods of conducting deposition cross-e...
Episode 167 - Schedule-Proofing Your Depositions: Drafting Notices with Multiple Backup Plans
In this episode, Jim Garrity - the leading expert in the country on deposition strategies and tactics - rolls out another spectacular deposi...
Episode 166 - Are You Audiorecording Your Depositions (Yet)?
In this episode, Jim Garrity urges you once again (see Episode 7, Audiotaping Your Depositions) to independently audiorecord your deposition...
Episode 165: Stopping the "You Can Answer" Gatekeeping
A must-listen episode with actionable guidance for litigators and trial teams who want to keep depositions moving and the record clean. We b...
Episode 164 - In-Person Depositions Are Making a Comeback
They're baaaaack! In-person depositions, that is. In this episode, Jim Garrity discusses two brand-new court rulings that reflect a growing...
Episode 163: Lessons from the Front Lines - Pronoun Perils: In 30(b)(6) Depos, “I” is the Entity, Not the Deponent
When a 30(b)(6) representative is deposed, the testimony is that of the organization, not of the individual answering the questions. However...
Episode 162 - Your Mute Button is Career Insurance
In this episode, Jim Garrity uses a pending bar disciplinary proceeding against a Florida lawyer as a potent reminder of the consequences of...
Episode 161: Unfinished Testimony - Can You Use That Partial Transcript?
Today, Jim Garrity examines a critical issue in trial practice: whether an incomplete deposition—cut short when the deponent becomes unavail...
Episode 160 - Depo Case Roundup for the Week of August 25, 2025
This week’s roundup spotlights four brand-new deposition rulings from across the country. Two address when plaintiffs may appear remotely—wh...
Episode 159 - Lessons from the Front Lines: Budget-Friendly Depositions: Using a Videographer to Tape & Transcribe Depositions
Are deposition expenses busting your budget? In this episode, Jim Garrity spotlights a clever strategy conceived by a southern California li...