HeyJared10,000 Depositions Later Podcast
From Jim Garrity, the country’s leading deposition expert, comes this podcast for hardcore litigators. The subject?
- Indexed episodes, last 90 days
- 5
- Latest publication
- Sep 24, 2026
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- Earliest in this view
- Jul 10, 2026
Latest episodes
Episode 180 - A Deposition Noticed for Remote Examination Doesn’t Prevent you from Attending in Person (opens the original)
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It's a common question. If the examining lawyer says they're going to depose witnesses by remote video, and notices it that way, does this obligate you (and all other counsel) to likewise appear remotely? Or can you still freely appear in person if you wish? Listen in for critical insights into the issue, supported, as always, by research on point in the show notes, including both cases and citations to applicable rules. Thanks for listening! SHOW NOTES Thomas v. Communication Workers of America
Episode 179 - Ten Per Side, Not Ten Per Party: The Deposition Limit That Surprises Many Litigators (opens the original)
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Well, here's a surprise for you. Did you know that in federal court - and in jurisdictions that follow or apply the federal rules, such as state courts, arbitrations, or administrative proceedings - the rules impose a limit of ten depositions per side , not per party ? Jim Garrity says that whenever he mentions this in casual conversations, many litigators react with surprise - as if he's lost his marbles. So, listen in for a 12-minute primer on this black-letter rule that's been in place now fo
Episode 178: How to Revoke Invocation of the Fifth Amendment Privilege After a Deposition (opens the original)
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You know how to assert a Fifth Amendment privilege in a deposition. But how to withdraw it, once the threat of criminal prosecution is gone? It's a dangerous minefield for the uninformed. In this episode, Jim Garrity explains the process, backed by both brand-new and enduring case law. Invaluable stuff, with a long list of supporting cites in the show notes for your research files. SHOW NOTES: United Healthcare Services, Inc. v. Mortazavi, et al., No. 3:21=cv=1547-L, 2026 WL 2076020 (N.D. Tex. J
Episode 177 - Lessons from the Front Lines: Touhy or Not Touhy? The Difficulties of Deposing Federal Employees (opens the original)
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In this episode, Jim Garrity explains the procedure for deposing current or former federal government employees where the federal government isn't a party to your litigation. These are commonly known as 'Touhy witnesses." And if they're important to your case, you'd better plan for their deposition very carefully. Garrity also discusses the importance of a strong backup plan, because many such deposition requests are denied by the employing agency. Important stuff to know! And great resources in
Episode 176 - You Don't Have to Prepay Experts Before Their Deposition (opens the original)
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How many times have you noticed an expert witness for deposition, only to be told you've got to pay their fee in advance, failing which, they say, they aren't coming. As Jim Garrity explains, it doesn't have to be that way. Listen in and learn why prepayment isn't required and how to properly avoid advance payment. After all, those prepayment demands are often excessive, don't explain how the fee was determined, and of course don't guarantee the expert will even qualify as such, much less offer
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