One of the most important aspects of complex civil litigation is the use of discovery depositions. Every trial lawyer uses discovery as an important component of his or her case development strategy in order to be more effective during trial. For the complex civil litigator, the deposition is key. Complex civil litigation involves numerous fact witnesses, numerous expert witnesses, thousands of pages of document production, all squeezed into a very specific area of the law. The following analysis is primarily a review of the Florida Rules of Professional Conduct, which closely mirror the ABA rules.
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