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

[Derek Manners]

I am no means an expert on this as I'm still a law student. However, I've worked at the Connecticut Attorney General's office for the last year and have been to two depositions where we have presented complex mathematical calculations in a residential mortgage backed securities underwriting case based on violations of the blue skies laws. 

The response we often got the first time we just dropped it on the defendants was that they'd need to get back to us once they'd had a chance to look at the data in more detail. 

The next time we had a deposition with this bank, we told them in advance that we'd be discussing numbers and they asked us to provide them in advance if they wanted a meaningful dialogue about them at the deposition. 

I'd imagine that talking to the other side and letting them know that if they have any material like you described and weren't planning to share ahead of time, that your client would not be able to discuss the relevant evidence until you've had a chance to look at it in an accessible form/had someone in your office look at it. 

Just my very new and humble opinion. 

Best wishes
Derek Manners

Sent from my iPhone

> On Apr 22, 2015, at 1:10 PM, Rod Alcidonis via blindlaw <blindlaw at nfbnet.org> wrote:
> 
> 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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