Episode 173 - Improper Preliminary Instructions or "Ground Rules"

10,000 Depositions Later Podcast by Jim Garrity

Jun 11, 202614:46Business

Have you ever had a queasy feeling, as an examining lawyer is explaining the so-called ground rules for the deposition with your witness, that something about the instructions was amiss? But you weren't quite sure what t...

Related Episodes

Continue listening to more episodes from 10,000 Depositions Later Podcast.

Episode 178: How to Revoke Invocation of the Fifth Amendment Privilege After a Deposition

Jul 31, 2026 - 23:19

You know how to assert a Fifth Amendment privilege in a deposition. But how to withdraw it, once the thre...

Episode 177 - Lessons from the Front Lines: Touhy or Not Touhy? The Difficulties of Deposing Federal Employees

Jul 21, 2026 - 18:36

In this episode, Jim Garrity explains the procedure for deposing current or former federal government emp...

Episode 176 - You Don't Have to Prepay Experts Before Their Deposition

Jul 10, 2026 - 8:40

How many times have you noticed an expert witness for deposition, only to be told you've got to pay their...

Episode 175: Lessons from the Front Lines: "We Outsourced It" - Countering the 30(b)(6) Ignorance Defense

Jun 26, 2026 - 11:14

What to do when an organization resists your efforts to conduct a Fed. R. Civ. P. 30(b)(6) deposition by...

Episode 174 - Lessons From The Front Lines: In-Person Depos are the Default Again (And a Psychological Reason for Insisting On Them)

Jun 17, 2026 - 16:54

In this episode, we feature a brand-new deposition-related ruling that continues to build on the post-COV...