Appendix 5-3 Deposition Preparation—attorney Checklist
| Library | Civil Discovery in Virginia (Virginia CLE) (2021 Ed.) |
__________ Review the initial pleadings. List causes of action and defenses below
__________
__________ Review relevant case law to support each cause of action and each claimed defense (list below)
__________
__________ Review relevant statutes (list below)
__________
__________ Review relevant jury instructions (list below)
__________
__________ Speak to expert witness (list below)
__________
__________ Create a flow chart of the elements of proof...
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