CASE ANALYSIS: Nov 8 - $25 Million Hospital Sex Assault With Horrific Pre-Existing & No Punitive Damages - Jessica Brylo & Eric Rosen

Darryl Isaacs

TLU n Demand

Trial Skills Training

Webinar Schedule

Mark Kosieradzki

Kosieradzki Law Firm

It has been said that we are from whence we came. I am the son of Polish immigrants. I didn’t learn to speak English until I was four. Coming from an immigrant family, my cultural life experience was different from the other kids. I didn’t really fit in. At the time I didn’t get it, but in retrospect, I realize that being different liberated me from having to fit a particular mold. My parents taught me that hard work, ingenuity, and perseverance were the keys to survival. Of course, I had no idea what that meant growing up. I just knew that I got my butt kicked more often than I could count, but I kept getting up and trying again. Over time I learned that to

As I embarked on the journey of becoming a trial lawyer, I again experienced getting my butt kicked. It soon became clear that lawyering the way everyone else did often resulted in being outmaneuvered by my adversaries (and by my competitors). I learned that if you always go with the flow, you will often flow down the drain. So, following the teachings of my father, ingenuity was my vehicle to develop better ways to solve the problems that we face as lawyers.

As a trial lawyer I needed evidence to even get to a jury.My adversaries were doing everything they could to prevent me from getting that evidence. So, I had to learn how to get past the bullies. I learned the rules of deposition engagement. Then, I learned that mastering Rule 30(b)(6) depositions enabled me to extract information from recalcitrant corporations and the government. I learned that the Rules of Civil Procedure and Evidence were not hoops to jump through but rather tools to bring structure to the marshalling of the facts.

Most importantly, I learned that by mastering the rules and acting like a professional, I was able to marshal the evidence necessary to win cases while simultaneously bringing the temperature down.It was easier to sleep at night.It was easier to find time to do things to enrich life. In addition to successfully representing my clients I was able to find time to live a life. At 50 I learned how to play the blues harmonica. At 63 I took up salsa dancing in Havana. At 66 I rode a bicycle the length of Puglia, Italy. The adventures keep coming.

My daughter convinced me that I should share what I had learned with other lawyers who face the same challenges that I did by writing practical and accessible books to stop the nonsense.

It is my hope that as my legacy I empower lawyers not to be afraid of goliath, that I empower them to do their jobs, to bring professionalism back to our profession, and finally, to enable them to recapture those hours and days lost to dealing with obstructionists.

Mark Kosieradzki

Holding Lawyer’s Personally Responsible for Evasive Discovery Responses

DEALING WITH OBSTRUCTION

Mark Kosieradzki will release his latest book Litigation Obstruction: Breaking Through at the TLU Live on June 5, 2024 in Huntington Beach. Mark is one of the nation’s foremost experts on discovery technique, strategy, and law. You can’t win motions to compel unless you understand the rules of engagement in discovery. During TLU Live Mark will distill down countless complex discovery topics to digestible bits that will help guide you ensure that you get the discovery you are entitled to.

Session 2: Holding Lawyer’s Personally Responsible for Evasive Discovery Responses

Lawyers have a duty to ensure that responses to discovery requests are complete. If all discoverable information is not produced and/or there are spurious objections, in addition to Rule 37 motions to compel, the responding lawyer can face personal sanctions for the inadequate discovery response. This session will explain the duties and the consequences for lawyers who fail those duties.

Mark Kosieradzki

Rules of Discovery Engagement

DEALING WITH OBSTRUCTION

Session 1: Rules of Discovery Engagement

You don’t have to accept defendant’s objections and evasive discovery responses. Session 1 will explain, how to craft bulletproof, relevant, proportional discovery and then arm you with the tools you need to put a stop to boilerplate objections and evasive responses.

Mark Kosieradzki

How to Win Motions to Compel

DEALING WITH OBSTRUCTION

Session 3. How to Win Motions to Compel

In Session 3 Mark will unveil a new litigation tool of templates and software that streamlines your motions to compel in a way that makes it easy for the judge to see the obstruction and rule in your clients’ favor. The obstruction management tool, paired with the included conferral templates, template brief and supporting documents creates an easy, streamlined process and eliminates what used to be a logistical nightmare. With just a few clicks, the software program organizes opposing counsel’s endless boilerplate objections into a manageable database.