# Jim Garrity

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Episode 173 - Improper Preliminary Instructions or "Ground Rules"

Have you ever had a queasy feeling, as an examining lawyer is explaining the so-called ground rules for the deposition with your witness, that something about the instructions was amiss? But you weren't quite sure what to say - and didn't really know whether or how to object? Instructions like, "C…

Talk of the Town June 22, 2026

President and CEO of the Morgantown Area Partnership with an update on the East End Village redevelopment project. Triple A spokesman Jim Garrity with a Fourth of July travel forecast Ethan Collins with a World Cup updaye.

Episode 176 - You Don't Have to Prepay Experts Before Their Deposition

How many times have you noticed an expert witness for deposition, only to be told you've got to pay their fee in advance, failing which, they say, they aren't coming. As Jim Garrity explains, it doesn't have to be that way. Listen in and learn why prepayment isn't required and how to properly avoi…

Episode 177 - Lessons from the Front Lines: Touhy or Not Touhy? The Difficulties of Deposing Federal Employees

In this episode, Jim Garrity explains the procedure for deposing current or former federal government employees where the federal government isn't a party to your litigation. These are commonly known as 'Touhy witnesses." And if they're important to your case, you'd better plan for their depositio…

Episode 178: How to Revoke Invocation of the Fifth Amendment Privilege After a Deposition

You know how to assert a Fifth Amendment privilege in a deposition. But how to withdraw it, once the threat of criminal prosecution is gone? It's a dangerous minefield for the uninformed. In this episode, Jim Garrity explains the process, backed by both brand-new and enduring case law. Invaluabl…

Talk of the Town September 8, 2026

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Elowyn Corby from Vote Solar on corporate governance changes they would like to see PJM make. Greg Hunter on the WVU Coastal Carolina game and remembering Chris Gray, the former WVU quarterback killed in the 9/11 attacks in New York City. Jim Garrity from Triple A Mid Atlantic on oil and gas prices

Episode 179 - Ten Per Side, Not Ten Per Party: The Deposition Limit That Surprises Many Litigators

Well, here's a surprise for you. Did you know that in federal court - and in jurisdictions that follow or apply the federal rules, such as state courts, arbitrations, or administrative proceedings - the rules impose a limit of ten depositions per side, not per party? Jim Garrity says that wheneve…

Episode 181 - Is Your Remote Deponent Using An AI Chatbot?

You won't want to miss this blockbuster episode on the increasingly common use of artificial intelligence platforms or chatbots to assist them in testifying during remote depositions. It's a serious problem now, and one that's only going to grow over time. Jim Garrity discusses the problem, offer…

Episode 182 - "Certify the Question!" Wait. What?

Ever heard a lawyer state "Certify the question!" to the reporter during a deposition, and wonder what it means? Wonder no more! Today, Jim Garrity explains the maneuver, its history, and why it could have value for you. "Certifying a question" is considered arcane by some, because it's no longer…