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Transcript of 1 How to Take Exceptional Depositions Video Depositions Louisiana Association for Justice October 9,...
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How to Take Exceptional Depositions
Video Depositions
Louisiana Association for JusticeOctober 9, 2014
Robert E. Kleinpeter
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Jury Instruction
A following motorist who rear ends the vehicle in front of him is presumed to breach the standard of care set forth in La. R.S. § 32:81.
To avoid liability, the burden of proof is on the rear-ending motorist to show that he kept his vehicle under control, watched the vehicle in front of him closely, and kept a safe distance, or that the lead driver created a hazard which he could not reasonably avoid.
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• Show an affirmative defense is baseless
• File or defeat motions
• Support your expert’s
conclusions
• Support your client’s harms and
losses
• Address juror biases
Written Case Discovery Plan
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1.Care
2.Fairness
3.Authority
4.Sanctity
5.Loyalty
Moral Foundations - Positive
MoralFoundations.org
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1.Harm
2.Cheating
3.Subversion
4.Degradatio
n
5.Betrayal
Moral Foundations - Negative
MoralFoundations.org
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1. Personal Responsibility (Accountability)
2. Suspicion
3. Anti-Plaintiff
4. Victimization
5. Stuff Happens
Five Juror Biases –The Jury Bias Model
Greg Cusimano and David Wenner
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• Facial expressions
• Body movement
• Posture
Why Use Video Depositions
• Gestures
• Eye contact
• Voice