Episode 6 - Using FRE 612 to Obtain Documents Used by Deponents to Refresh Recollections
From 10,000 Depositions Later Podcast · 3:13
Show by Jim Garrity
The documents reviewed by deponents in order to refresh their recollections, before their upcoming testimony, can be of critical value. What did they look at? Is it something you even knew existed? You may need to get your hands on them. But there's a right way, and a wrong way, to lay the foundation in order to compel their production. In this podcast, we explain how to do it, using Federal Rule of Evidence 612.SHOW NOTES (Added after original episode publication date)J & R Passmore, LLC, et al. v. Rice Drilling D, LLC, 2021 WL 4810150 (S.D. Ohio Oct. 15, 2021) (court deemed attorney-client privilege waived as to meeting minutes and emails used by corporate representative to refresh her recollection for the purpose of testifying in deposition)
More episodes of 10,000 Depositions Later Podcast
More episodes
- Episode 182 - "Certify the Question!" Wait. What?
- Episode 181 - Is Your Remote Deponent Using An AI Chatbot?
- Episode 180 - A Deposition Noticed for Remote Examination Doesn’t Prevent you from Attending in Person
- Episode 179 - Ten Per Side, Not Ten Per Party: The Deposition Limit That Surprises Many Litigators
- Introduction and Welcome to the Podcast!
- Episode 2, Part 1 - Tools for Capturing Testimony
- Episode 2, Part 2 - Tools for Capturing Testimony
- Episode 3 - "I Demand A Yes or No Answer"
- Episode 4 - What is the "Right" Style for Deposing Witnesses?
- Episode 5 - "Legal Contention" Questions in Depositions
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