Presentation on theme: "1 How to Take Exceptional Depositions Video Depositions Louisiana Association for Justice October 9, 2014 Robert E. Kleinpeter."— Presentation transcript:
1 How to Take Exceptional Depositions Video Depositions Louisiana Association for Justice October 9, 2014 Robert E. Kleinpeter
5 An Important Legal Equation E + L = V
7 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.
9 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