Key Strategies for Case Preparation: Depositions and medical records summaries, use of motions in limine, and fact witness and expert witness preparations

Doug P. Holthus
Doug P. Holthus | Freeman Mathis & Gary, LLP

Doug Holthus is a Partner and Office Chair of Freeman Mathis & Gary's Columbus, Ohio office and a member of the Firm's On Call Trial team.

On-Demand: April 22, 2024

2 hour CLE

Tuition: $195.00
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Program Summary

There simply is no substitution for preparation. While your opposing counsel may think they know their case, you will know yours better. Not only the operative details and facts, but also the law applicable to each claim and all defenses. During this brief program, we will discuss four principal strategies to prepare your case for trial and create leverage for an opportunity to bring home a successful verdict or promote settlement during trial.

Key topics to be discussed:

  • Deposition and medical records summaries are not substitutes
  • Use of motions in limine
  • Fact witness preparation
  • Expert witness preparation

Closed-captioning available

Speakers

Dough-P.-Holthus_Freeman-Mathis-&-Garys_myLawCLEDoug P. Holthus | Freeman Mathis & Gary, LLP

Doug Holthus is a Partner and Office Chair of Freeman Mathis & Gary’s Columbus, Ohio office and a member of the Firm’s On Call Trial team. He is also Chair of the firm’s Midwest Coverage practice team. Mr. Holthus’ primary areas of focus are the defense of general tort/general liability claims, the defense of commercial claims, the defense of private and public employers in labor and employment disputes (including federal and state claims of discrimination, retaliation, and harassment/hostile work environment claims), the defense of sex/human trafficking claims, construction claims defense litigation, and the defense of civil rights claims and other governmental entity liability issues. Doug also handles commercial disputes and general liability matters. He has tried, advocated and or arbitrated nearly one hundred cases before civil juries, administrative licensing (and other) boards and arbitration panels throughout Ohio (as well as Illinois, Michigan, and California), in both state and federal court.

Doug serves as Vice-Chair of the Ohio Academy of Civil Trial Attorneys (“OACTA”) Employment Practice Section, has served as Chair of the Columbus, Ohio Bar Association’s Professionalism Committee and is a past Member of the Board of Directors of the Professional Liability Defense Federation (“PLDF”). Doug is also a member of the American Board of Trial Advocates (“ABOTA”). Doug is “AV Preeminent Rated” by Martindale-Hubbell, as well as named a “Best Lawyer” by Best Lawyers in America.

Agenda

I. Deposition and medical records summaries are not substitutes | 12:00pm – 12:30pm

II. Use of motions in limine | 12:30pm – 1:00pm

Break | 1:00pm – 1:10pm

III. Fact witness preparation | 1:10pm – 1:40pm

IV. Expert witness preparation | 1:40pm – 2:10pm

Credits

Alaska

Approved for CLE Credits
2 General

Our programs are CLE-eligible through Alaska's recognition of multi-jurisdictional reciprocity.
Alabama

Pending CLE Approval
2 General

Arkansas

Approved for CLE Credits
2 General

Our programs are CLE-eligible through Arkansas's recognition of multi-jurisdictional reciprocity.
Arizona

Approved for CLE Credits
2 General

California

Approved for CLE Credits
2 General

Colorado

Pending CLE Approval
2 General

Connecticut

Approved for CLE Credits
2 General

District of Columbia

No MCLE Required
2 General hours

Delaware

Pending CLE Approval
2 General

Florida

Reciprocity
2.5 General Hours

Receive CLE credit in Florida via reciprocity
Georgia

Approved for CLE Credits
2 General

Hawaii

Approved for CLE Credits
2 General

Iowa

Pending CLE Approval
2 General

Idaho

Pending CLE Approval
2 General

Illinois

Approved for Self-Study Credits
2 General

Indiana

Pending CLE Approval
2 General

Kansas

Pending CLE Approval
2 General

Kentucky

Pending CLE Approval
2 General

Louisiana

Pending CLE Approval
2 General

Massachusetts

No MCLE Required
2 General

Maryland

No MCLE Required
2 General

Maine

Pending CLE Approval
2 General

Michigan

No MCLE Required
2 General

Minnesota

Approved for Self-Study Credits
2 General

Missouri

Approved for Self-Study Credits
2.4 General

Mississippi

Pending CLE Approval
2 General

Montana

Approved for Self-Study Credits
2 General

North Carolina

Pending CLE Approval
2 General

North Dakota

Approved for CLE Credits
2 General

Our programs are CLE-eligible through North Dakota’s recognition of multi-jurisdictional reciprocity. Section 1, Policy 1.14
Nebraska

Pending CLE Approval
2 General

myLawCLE reports attendance to Nebraska on each attorney's behalf for all programs. Please do not self-report.
New Hampshire

Approved for CLE Credits
120 General minutes

As of July 1, 2014, the NHMCLE Board no longer provides pre- or post-approval of courses. Attendees must self-determine whether a program is eligible for credit, and self-report their attendance online at www.nhbar.org, based on qualification provisions of Rule 53.
New Jersey

Approved for CLE Credits
2.4 General

Our programs are CLE-eligible through New Jersey's recognition of multi-jurisdictional reciprocity, except for the courses required under BCLE Reg. 201:2
New Mexico

Approved for Self-Study Credits
2 General

Nevada

Approved for Self-Study Credits
2 General

New York

Approved for CLE Credits
2.4 General

Our programs are CLE-eligible through New York’s Approved Jurisdiction Group “A”.
Ohio

Approved for Self-Study Credits
2 General

Oklahoma

Pending CLE Approval
2.5 General

Oregon

Pending CLE Approval
2 General

Pennsylvania

Approved for Self-Study Credits
2 General

Rhode Island

Pending CLE Approval
2.5 General

South Carolina

Pending CLE Approval
2 General

South Dakota

No MCLE Required
2 General

Tennessee

Pending CLE Approval
2 General

Texas

Pending CLE Approval
2 General

Utah

Pending CLE Approval
2 General

Virginia

Not Eligible
2 General Hours

Vermont

Approved for CLE Credits
2 General

Washington

Approved via Attorney Submission
2 Law and Legal Hours

For CLE course attendance credit, Washington state attorneys must self-apply to the Washington State Bar. myLawCLE will supply Washington state attorneys with the self-application package and instructions on how to gain credit.
Wisconsin

Approved for Self-Study Credits
2 General

West Virginia

Pending CLE Approval
2 General

Wyoming

Pending CLE Approval
2 General

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