[blindlaw] Defending civil deposition alone -- dealing with diagrams and photographs?

[Gerard Sadlier]

I'd be really grateful to be included in any discussions on this via
email (either on or off the list). I'm very interested and will of
course be happy to preserve confidentiality, as required.

Rod,

I haven't myself done this as I'm newly qualified and anyway Irish
civil procedure does not have anything quite akin to the American
deposition.

However, it seems to me that any lawyer (blind or sighted) will want
access to such material before the hearing, so that they can prepare
their examination of the witness, whether that be in chief or in
cross. Otherwise, there is a risk that the lawyer will be taken by
surprise and may fail to adequately obtain client's instructions (or
guidance from experts, if appropriate - as where the diagrams relate
to technical subject matter for example).

I therefore wonder whether there is some means under the applicable
rules, by which you can obtain the material prior to the deposition?
Failing that, I wonder whether an application could be made to Court -
I do not see why one should be reluctant to rely on one's disability
for the purpose of obtaining material in advance.

Those are just my thoughts.

Ger

On 4/22/15, Stephen Alexander Marositz via blindlaw <blindlaw at nfbnet.org> wrote:
> If anyone has ideas, can you share them with the list?  I am curious about
> this as well.
>
> -----Original Message-----
> From: blindlaw [mailto:blindlaw-bounces at nfbnet.org] On Behalf Of Rod
> Alcidonis via blindlaw
> Sent: Wednesday, April 22, 2015 10:10 AM
> To: NFBnet Blind Law Mailing List
> Subject: [blindlaw] Defending civil deposition alone -- dealing with
> diagrams and photographs?
>
> Colleagues:
>
> Would like to pick the brain of someone who has defended civil depositions
> without an assistant. Want to develop strategy to deal with photographs and
> diagrams that will be presented to the witness, and in some cases, I would
> not have had them in advance to review.
>
> Please contact me off-list or I will contact you to chat over the phone.
>
> Appreciate all help...
>
> Rod
> 215-821-6015
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