Discovery Best Practices for California Personal Injury Lawyers: Disclosing Non-Economic Damages Witnesses the Right Way

Few discovery questions generate as much disagreement among plaintiff-side practitioners as how to answer a special interrogatory asking for the witnesses who can speak to a client’s pain and suffering, emotional distress, and other non-economic damages. I’ve watched this argument play out among colleagues more… read more

Videotaped Depositions: Key Tool for Personal Injury and Car Crash Cases

Videotaped depositions are one of the most underutilized tools in California personal injury practice. Most plaintiff attorneys record depositions as a matter of course — but few use them to their full strategic potential. This post covers the statutory framework, the availability rules that most… read more