By Stacy Phillips and Ram Cogan
Every experienced litigator has had that poignant moment when defending a client's deposition at which he or she recognizes the need for immediate action. With heartbeat racing, we calmly ask for a break, summon our client into the hallway and, while out of sight, grab our client by the lapels (sometimes literally) and emphatically ask: "What are you doing?" It is with no less a sense of urgency, although far more graciously and politely, t...
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