We all know that the only things you can rely on are “death and taxes” and, unfortunately, during a pandemic the former may hit close to home. As such, the conventional wisdom of not noticing your own witness' deposition may be dangerously wrong…
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Attorneys fret when receiving an “I don’t recall” answer in deposition and try to ensure the witness cannot wiggle out of the response at trial. But what if you receive an “I don’t recall” in a written discovery…
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