Monday, February 23, 2015
Depositions to Establish Foundational Facts
A while back, I discussed using requests for admissions to establish foundational facts for a case. Likewise, depositions can be used for that purpose. I like to use depositions to establish facts regarding documents. This can be used to authenticate them and get admissions that the opposing party is not aware of any material alterations to the documents. This can make it really hard for the other side to undermine the document later when they admit it is accurate in a deposition.