About this episode

Jim Garrity discusses the implications of improper preliminary instructions during depositions and how to object to them.

Have you ever had a queasy feeling, as an examining lawyer is explaining the so-called ground rules for the deposition with your witness, that something about the instructions was amiss? But you weren't quite sure what to say - and didn't really know whether or how to object? Instructions like, "Can we agree that if you answer a question, it means you understood it?", and "Will you agree to limit your testimony to actual facts you personally know to be true, and not answer based on speculation or opinion?" can box your client in, cause them to omit important information, and do grave damage at later evidentiary hearings or trials. In this episode, Jim Garrity explains how these kinds of instructions may be improper and how to articulate your objections. It's a definite don't-miss.

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