Publications

"Deposition Strategy and Tactics: Trout Spots, Assorted Knots and Favorite Tricks of a Fisherman," 23 Texas Trial Lawyers Forum 1 (1988);

"Strategic and Tactical Considerations for Use of Depositions at Trial," 7 The Advocate No. 2 (State Bar Litigation Section Report, Oct 1988); (1988); (1990);

Special Editor, The Advocate No. 2, State Bar Litigation Section Report (October, "Personal Injury Actions Under the DTPA," (Co-Author), St. Mary's Law Journal

"Organizing Discovery for Trial," The Ultimate Trial Notebook (Texas State Bar Convention, June 1989, 1990, 1991,1992).

"Deposition Strategy and Tactics," Excellence in Advocacy (National College of Advocacy 1992);

"Discovery in Texas," State Bar of Texas (1993)

Papers and Presentations:

"Discovery Update: Reports from the Muck," Litigation Update; State Bar of Texas (1992);

"Rooting for Acorns 1992 Updatefrom the Muck," Advanced Personal Injury; SouthTexas College of Law (1992);

"Designating Experts and Other Discovery Traps/Oz Update," 3rd Annual Medical Malpractice Conference, Texas Trial Lawyers Association (1992);

"Thoughts on Planning Discovery for Trial, In the Aftermath of the Mother of AU Battles," Young Lawyers Trial Practice Seminar, American Bar Association (1992);

"Discovery Techniques & Considerations for Enhancing Trial Success: A DogSoldier's Lessons Learned from Discovery Wars," Personal Injury and Products Liability Seminar, Southern Methodist University (1992);

"Packaging Discovery for Trial," 5th Annual Advanced Evidence & Discovery Course, State Bar of Texas (1992) #5

"Scope of Discovery," Litigation Update, State Bar of Texas (1993);

"Discovery in Texas: Rooting for Acorns," One-Day Institute, State Bar of Texas (1993);

"Discovery in Texas: Rooting for Acorns," Advanced Personal Injury Course, State Bar of Texas (1988-1995);

"Discovery Update," Advanced Civil Trial Course, State Bar of Texas (1993, 1995);

"Discovery Update: Scope of Discovery in Texas 1994," Texas Trial Lawyers Association, Dynamic Advocacy (1994);

"Discovery Strategies: Use of Video Depositions," Winning with the Masters, Louisiana Trial Lawyers Association (1994);

"State of the Art Discovery Techniques in Malpractice," Sth Annual Medical Malpractice Conference; Texas Trial Lawyers Association (1994);

"Discovery Objections and Requests for Protection: The Back Game," 20th Annual Advanced Family Law Course; State Bar of Texas (1994);

"Scope of Discovery in Texas 1994," Hot Tips for Hot Times, Texas Trial Lawyers Association (1994);

"Discovery Objections and Requests for Protection: The Back Game," The Ultimate Trial Notebook-Personal Injury Law, State Bar of Texas (1994);

"Discovery Update: Scope of Discovery in Texas 1994," Dallas Trial Lawyers Association (1994);

"Discovery in Texas: Rooting for Acorns 1994 Reports from the Muck," 10th Annual Advanced Personal Injury Law Course; State Bar of Texas (1994);

"Scope of Discovery in Texas 1994," Advanced Medical Malpractice Litigation; South Texas College of Law (1994);

"Discovery," The Litigation Short Course, Texas Trial Lawyers Association (1995);

"Discovery of Texas: Rooting for Acorns, 1995 Reports from the Muck," Advanced Personal Injury Course, Texas Trial Lawyers Association (1995);

"Discovery in Texas: Rooting for Acorns, 1995 Reports from the Muck,:" Mexican American Bar Association of Houston (1995);

"Privileges: Is Nothing Sacred Anymore?" Advanced Personal Injury Law Course; State Bar of Texas (1995);

"Discovery," 21st Annual Advanced Family Law Course, State Bar of Texas; (1995);

"Discovery in Medical Liability Cases," The Cutting Edge of Medical Liability, Southern Methodist University (1995);

"Discovery in Medical Malpractice Cases," 6th Annual Advanced Medical Malpractice Conference-, Texas Trial Lawyers Association (1995);

"Creative Use of Depositions," Trial Lawyers Trial Notebook featuring the Texas All-Stars; Texas Trial Lawyers Association (1995);

"Privileges-You Can't Have It!" 18th Advanced Civil Trial Course, State Bar of Texas (1995);

"The New Improved Discovery Rules: Anticipated Rule Changes Oat of the

Supreme Court Advisory Committee," Hot Tips for Hot Times, Texas Trial Lawyers

Association (1995);

"Premises Liability Update," Litigation 'Update Institute 1996, State Bar of Texas; (1996);

"Discovery Objections and Requests for Protection: The Back Game, "S,M,U, Advanced Civil Trial & Appellate Advocacy Course Seminar, Southern Methodist

University School of Law; (1996);

"Privileges in Texas," The University of Texas School of Law Evidence and Discovery Symposium (May 1996);

The Remaining Scope of Discovery," 7th Annual Texas Trial Lawyers Medical Malpractice Conference (1996);

"Scope of Discovery," University of Houston Advanced Evidence and Discovery Institute (1996);

"Privileges, Is Nothing Sacred Anymore?" South Texas College of Law Discovery

Practice Conference: Discovery in a New Age (1996);

"Talking Heads, Speaking Objections and the UsualAgreements: Procedural and

Practical Tips for Effectively Taking and Using Depositions," State Bar of Texas 9th

Annual Advanced Evidence and Discovery Course (Austin, Texas, May, 1996; Santa Fe, New Mexico, May 1997);

"Protecting/Piercing Privileges," South Texas College of Law Advanced Civil Law Conference (February 27, 1997);

"I'd Rather Be Fishing: The Evaporating Scope of Discovery in Texas," Premises Liability Seminar, Texas Trial Lawyers Association (February 29,1997);

"No Evidence, No Reason, No Justice: When is Enough?" A Critical Analysis o f the New Texas Rule of Civil Procedure 166a(I)," Practicing Law Under the New Rules of Trial and Appellate Procedure, Southern Methodist University School of Law & Matthew Render (November 7- 8,1997);

"New Discovery & Summary Judgment Rules," Advanced Civil Trial Law Conference, South Texas College of Law (February 6, 1998);

"Discovery Objections and Requests for Production:' Ultimate Trial Notebook, State Bar of Texas (February 27, 1998);

"Discovery, Pretrial Strategy & the New Rules," Advanced Medical Malpractice Panel Discussion, State Bar of Texas (March 27,1997);

"Deposition Strategies and Admissibility," Advanced Evidence & Discovery Course; State Bar of Texas (May 29,1998);

"The Now Proposed Rules of Discovery," Legal Assistants Division Seminar,

State Bar Convention (June, 1998);

"Advanced Discovery Strategies Workshop;" State Bar of Texas (July 9,1998);

"New Rules of Discovery," Advanced Personal Injury Law Course, State Bar of Texas (July 18, 1998, July 30,1998, August 13,1998);

"Advanced Discovery Strategies Workshop," Panel Discussion, State Bar of Texas (August 27,1999);

"Discovery Update: Cases and New Rules," Advanced Personal injury Course,

Texas Trial Lawyers Association (August, 1998);

"The New Proposed Discovery Rules," Houston Trial Lawyers Association (October, 1998);

"Depositions," 21" Annual Advance Civil Trial Course, State Bar of Texas (November, 1998);

"Doing Unto Others First," Ethical Discovery; B'nai Brith (November, 1998);

"Paper Mache': Drafting Effective Discovery Documents," 1 l ' Annual Advanced Evidence and Discovery Course, State Bar of Texas (November, 1998);

"Applying the New Rules of Civil Discovery- Practical Solutions from the Experts," (satellite transmission; estimated 2,400 participants, reported largest CIE course in history), State Bar of Texas CL E (November, 1998);

"New Discovery Rules," 5h Annual Para-Professional Program, Texas Trial Lawyers Association (December, 1998);

"New Rules of Discovery," Supreme Court New Rules of Discovery Conference Call, Texas Trial Lawyers Association (January 12, 14, 19, 1999);

"New Discovery Rules," University of Texas at Austin (January 22,1999íHouston; January 29, 1999-Austin; February 5,1999-Dallas);

"Plaintiff Tips and Strategies for Litigating Under the New Discovery Rules," Advanced Civil TrialLaw Conference, South Texas College of Law (February 4,1999);

"New Discovery Rules," Dallas Trial Lawyers Association (February 18,1999);

"Implementation of the New Discovery Rules," Advanced Personal Injury Course, Texas Trial Lawyers Association (May 7, 1999);

"The New Rules and Their Effects on Personal Injury Litigation," Houston Bar Association; Litigation Section (May 18, 1999);

"Depositions Under the New Rules, Including 3d Party Issues," Advanced Evidence and Discovery Seminar (May 28, 1999);

"Talking Heads, Potted Plants and Speaking Objections: Understanding the New Rules of Deposition Practice in Texas," 23d Advanced Civil Trial Course, State Bar of Texas (August, September, November 2(00);

"So Who Died and Made You King?" How and When to Ask the Right Question about Experts Under Texas' New Discovery Rules," Advanced Evidence and Discovery Law Course, Texas Trial Lawyers Association (November 18-19,2000);

"Use of Depositions in the Courtroom," The Ultimate Trial Notebook, State Bar of Texas (June 23, 2000);

"Running and Gunning for Justice: Strategies for Formulating and Implementing Scheduling Orders in Medical Malpractice Claims: Lessons Learned from the "Hurry Up" Offense," Masters of Trial Seminar, Houston Triad Lawyers Association (November 10, 2000);11th Annual Medical Malpractice Seminar, Texas Trial Lawyers Association, South Texas College of Law (September 28-29, 2000);

"I'd Rather Be Fishing: Re-Visiting the Scope of Discovery in Texas After implementation of the New Discovery Rules," " Texas Trial Lawyers Association Product Liability Litigation Seminar, (February 22 - 23, 2001);

"Talking Heads, Potted Plants and Speaking Objections: Deposition Practice in Texas," and" So Who Died and Made You King?" Advanced Evidence and Discovery Course, State Bar of Texas (2002);

"So Who Died and Made You King?: Discovery of Experts in Texas," Masters of Trial, Houston Trial Lawyers Association, (2002);

"So Who Died and Made You King?: Discovery of Expects in Texas." Advanced Expert Witness Course III, State Bar of Texas (November, 2002, December, 2002, January 2003);

"Talking Heads, Potted Plants and Speaking Objections: Deposition Practice in Texas," and " So Who Died and Made You King'?" Advanced Evidence and Discovery Course, State Bar of Texas (2003);

" Discovery Update," College of the State Bar, State Bar of Texas, Galveston (July, 2003).

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