Advice to Young Lawyers: The Usual Deposition Stipulations
(right: practice, practice, practice) Take a look at Steven Archer's article on the Dangers of the Usual Stipulation for the reasons why the "usual" proposed stipulation is filled with traps for the unwary. Mr. Archer thoughtfully provides what he believes is a bullet-proof stip, which I'm providing below (with my contribution limited to reducing his stipulation to bullet points). Mr. Archer is a partner with the highly esteemed national law firm of Robins, Kaplan, Miller and Ciresi. Thanks to the always helpful Illinois Trial Practice Blog for introducing us to this helpful article in its own post -- Beware the Usual Stipulations. ...
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