CT Summation – Bow Tie Law

Back on the Record: Tips on Deposition Preparation with Technology

January 21, 2009 Josh Gilliland CT Summation, Deposition, Discovery, Document Review, e-Discovery

I have taken and defended a good number of depositions. Preparing for deposition requires thoroughness, thoughtfulness, and not being tied to your question outline like a student actor reading a script. Whether you are “old school” or “new school,” there are many ways to enhance your deposition practice with litigation[…]

Mock Motion in Limine Arguments to Exclude ESI

January 19, 2009 Josh Gilliland CT Summation, Deposition, Discovery, e-Discovery, Mock Trial, Native File, Trial

Michael Berman, Esq., of Rifkin, Livingston, Levitan & Silver, LLC, argued to excluded email messages and a voice mail at the CT Summation Best Practices Summit, held in Washington, DC on May 20th, 2008. The Best Practices Summit included a mock motion in limine hearing. In the fictional case, the[…]

Deposition Review with CT Summation iBlaze Color Highlighting

January 9, 2009 Josh Gilliland CT Summation, Deposition, Document Review, e-Discovery

You can open my old Civil Procedure course book and see I usually highlighted cases with three colors: Blue for the “Issue,” orange for “Rule,” yellow for “Analysis” and a note in the margin for the “Conclusion” (IRAC for the non-lawyers). Law students have been highlighting and writing in textbooks[…]

e-Discovery: Not like Reviewing a Box of Paper

January 7, 2009 Josh Gilliland Discovery, Document Review, e-Discovery, Request for Production

Treating e-Discovery review the same as a paper-based document review runs the risk of shattering the litigation process. In Oracle v. SAP, 2008 U.S. Dist. LEXIS 88319, the estimated cost of reviewing 165 custodians was projected as $16.5 million. This included the defendants employing more than fifty contract attorneys and[…]