Articles on Depositions

Comparison snapshot of Illinois state and federal depositions: Types of depositions and how they are used By Michael S. Seneca Federal Civil Practice, May 2005 Illinois state courts draw a distinction between a discovery deposition and an evidence deposition. Ill. S. Ct. Rule 202.
Deposition rules to improve your success on summary judgment motions By Timothy J. Howard Federal Civil Practice, May 2005 Whether you represent the plaintiff or the defendant, there is always at least one element of your case that you believe is subject to summary judgment.
Ten tips on taking a deposition By James F. Holderman Federal Civil Practice, May 2005 Although depositions typically come to a judge's attention only when rulings are needed or the deposition transcript is presented at trial, here are some practical thoughts I have developed from my years of practicing law and presiding on the bench that I believe all lawyers should consider in taking depositions.
Deposing the “master” By William J. Borah Labor and Employment Law, February 2004 It is not what the truth is, it is what we can prove."
The plaintiff’s deposition By Michael R. Lied Labor and Employment Law, February 2004 There are a number of things that defense counsel may hope to accomplish in the plaintiff's deposition. Counsel may want to both fully understand and seek to narrow the plaintiff's claims.
Recovery of evidence deposition and transcription costs: An update By Michael J. Marovich Civil Practice and Procedure, November 2003 In Vicencio v. Lincoln-Way Builders, Inc, 204 Ill.2d 295, 789 N.E.2d 290 (2003), the Illinois Supreme Court resolved a split in the lower courts as to whether a plaintiff may recover as taxable costs the professional appearance fees of a treating physician.
Witnesses, statements and depositions By Patrick M. Kinnally Civil Practice and Procedure, September 2003 I have been taking statements and depositions from people since 1975. First, it was in the context of working for a federal agency where sworn statements were used in enforcement proceedings before a federal administrative law judge.
Twelve tips for prepping employees for deposition By Michael Todd Scott Corporate Law Departments, November 2002 Most in-house counsel will at some time have to prep an employee for deposition.

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