Category Archives: Depositions

Paxton and Succession – What if you are the coup target?

Posted on September 25, 2023 by Joe Ahmad

Though politics, in the more formal political party sense of the word, had a leading role in the impeachment trial of Texas Attorney General Ken Paxton, there were definite similarities between that attempted takeover and what happens in the hit … Continue reading →

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Picture that text you just wrote on the screen in a courtroom

Posted on December 8, 2016 by Joe Ahmad

Executives know better than to put questionable statements in email, right? Well, it is past time to realize the same goes for texts. Just like a Miranda warning: Anything you text can and will be used against you in a court of law. Continue reading →

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Deposition tips for Camille Cosby

Posted on January 5, 2016 by Joe Ahmad

I work a lot with executives facing deposition in high-stakes commercial litigation, so I know what Bill and Camille Cosby’s legal team is doing right now: everything they can to quash the prospect that Mrs. Cosby will have to be … Continue reading →

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Executive Deposition Tips, Part 7: Practice Makes Perfect

Posted on September 27, 2011 by Joe Ahmad

The most important step in preparing for a deposition is a full-blown cross examination dress rehearsal—minus opposing counsel, of course. After I’ve coached my client on all the do’s and don’ts of depositions (click here to see previous Executive Deposition … Continue reading →

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Executive Deposition Tips, Part 6: Lose the Ego

Posted on September 13, 2011 by Joe Ahmad

Executives face several perils in a deposition, but perhaps none more perilous than their own egos. Few executives got where they are by being shy, retiring types. They probably achieved success the old fashioned way: by being disciplined, demanding, type … Continue reading →

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Executive Deposition Tips, Part 5: Ambiguities and Ventriloquism

Posted on August 30, 2011 by Joe Ahmad

When I’m preparing an executive for a deposition, I have to remind him or her that even though the deposition may be held in a run-of-the-mill conference room, it may as well be in a courtroom because what’s said there … Continue reading →

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Executive Deposition Tips, Part 4: Know Your Role in the Corporate Defense

Posted on August 16, 2011 by Joe Ahmad

If you work in the C-suite, then it is assumed that you have a thorough understanding of the workings of your company. So, it would make sense that executives would feel well equipped to handle any questions regarding the operation … Continue reading →

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Executive Deposition Tips, Part 3: Steer Clear of Innuendo

Posted on August 2, 2011 by Joe Ahmad

Executives might be tempted to aim disparaging comments at the opposing side during a deposition. Avoiding this urge can be difficult when opposing counsel is peppering an executive with questions impugning his or her credibility, competency and intellect. But resisting the … Continue reading →

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Executive Deposition Tips, Part 2: It’s Not a Basketball Game

Posted on June 1, 2011 by Joe Ahmad

 With the NBA Finals upon us, it seems appropriate to take up my continuing series of Executive Deposition Tips with this bit of advice: control the tempo. If you’re being deposed, you’re running out the shot clock. The opposing counsel, … Continue reading →

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Executive Depositions Tips, Part 1: Answer the Question

Posted on April 27, 2011 by Joe Ahmad

When I’m preparing my executive clients for a deposition, I turn on the recorder and ask them the following question: “Do you know what time it is?” The recorder is crucial in this exercise because the client—used to normal human … Continue reading →

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