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 deposition strategy you won't find anywhere else. It's the application of the PACE Method to your deposition scheduling. It will change how you draft your deposition notices forever. PACE - an acronym for Primary, Alternate, Contingency, and Emergency - was devised by the U.S. Military to ensure that if the primary plan goes haywire, there is a Plan B: an immediate go-to backup. And a Plan C, and a Plan D. It sharply increases the odds of mission success because there are no debates or delays when one plan fails. Everyone switches to the next layer of redundancy. Here, Garrity tells you how to apply PACE to deposition scheduling, so that when your primary plan for deposing a witness - say, an in-person deposition - cannot proceed, you (and all other participants) immediately switch to your alternate plans. As always, thanks for listening to the number podcast in the world devoted exclusively to deposition strategies and tactics for litigators handling civil, administrative, arbitrative, and criminal proceedings.

You can listen to Episode 167 - Schedule-Proofing Your Depositions: Drafting Notices with Multiple Backup Plans online on Radio and Podcast. Open the player on this page to stream the available audio.

Episode 167 - Schedule-Proofing Your Depositions: Drafting Notices with Multiple Backup Plans is an episode from 10,000 Depositions Later Podcast by Jim Garrity.

This episode is 13:08 long.

This episode was published on Feb 8, 2026.

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