Podcasts about WL

** PLEASE SUBSCRIBE ** Featured in WYGYFF Episode 20: Australian funk singer, composer and producer Traffik, who leads a four-member band of the same name. The group's recently released album, “The Signs,” is a powerful mix of funk and rock that was 10 years in the making. Traff has also paired up with guitarist/engineer Simon Russell as the duo Eddie Metal, kicking off a series of instrumental recordings. Both are flying under the new Funkoditionalove independent record label banner. He talks about those projects as well as his profound experiences with George Clinton and members of Parliament-Funkadelic. They inspired him to rename Melbourne as Smellbourne. Dig this tale of finding the funk Down Under. Check out his documentary here https://www.youtube.com/watch?v=P70juildJwY&list=WL&index=9&t=4s&ab_channel=funkonditionalove. RECORDED FEBRUARY 2025 Hosted by Scott "DR GX" Goldfine — musicologist, author of “Everything Is on the One: The First Guide of Funk” and creator/host of the popular TRUTH IN RHYTHM podcast — "Where'd You Get Your Funk From?" is the latest interview show brought to you by FUNKNSTUFF.NET. Where'd You Get Your Funk From (WYGYFF) is an open format video and audio podcast focusing on the here and now, with a broad range of creative and artistic guests sharing fascinating stories, experiences, and perspectives. WYGYFF is a welcoming avenue to newer and independent musical acts as well as established and still active musicians of any genre; authors; filmmakers; actors; artists; collectors and archivists; radio & podcast personalities; journalists; scholars; sound techs; promoters; photographers; and other creative people. A common thread, is the show's standard opening question: Where'd you get your funk from? This is much deeper than it may seem as the answer need not be strictly about funky music, as not everyone has found the funk. It could hit on whatever type of music touches their soul or pleasure centers. Additionally, the question extends beyond music. Paraphrasing George Clinton, funk is whatever it needs to be to get you over the hump. Thus, guests can explain where they got their grit, perseverance, inspiration, talent, creativity, character or other qualities that shaped them into who they are today. This serves as a springboard into candid, in-depth and engrossing conversations. LEGAL NOTICE: All video and audio content protected by copyright. Any use of this material is strictly prohibited without expressed consent from original content producer and owner Scott Goldfine, dba FUNKNSTUFF. For inquiries, email info@funknstuff.net. Get your copy of "Everything Is on the One: The First Guide of Funk" today! https://www.amazon.com/gp/product/1541256603/ref=as_li_tl?ie=UTF8&camp=1789&creative=9325&creativeASIN=1541256603&linkCode=as2&tag=funknstuff-20&linkId=b6c7558ddc7f8fc9fe440c5d9f3c400

A wealthy couple is murdered after a glamorous party—jewelry stolen, town abuzz. Their estate files an HO3 claim for the stolen jewelry and loss in home value due to the stigma. But does the policy cover reputational "diminution in value"?   Notable Timestamps [ 00:37 ] - The scenario involves a wealthy couple poisoned in their mansion, with jewelry stolen and a claim submitted under their HO3 policy ISO 2011 edition. [ 01:39 ] - Trivia Time! Who are the six main characters of the board game Clue? [ 03:40 ] - Diminution in value refers to a property's market value being less than before a loss, even after full physical repair, due to stigma. [ 04:35 ] - The common argument against covering diminution in value is that policies typically cover physical loss and physical repair, not consequential or economic losses. [ 06:16 ] - First-party auto and property policies share similar loss settlement language. [ 07:47 ] - In Royal Capital Dev., LLC v. Maryland Cas. Co., No. S12Q0209, 2012 WL 1909842, — S.E.2d — (Ga. 5/29/12) [reviewed at PLRB, Prop. Ins. L. Rev. 8462 (2012)], the court allowed for diminution in value in a first-party property claim, drawing an analogy to auto claims. [ 08:50 ] - If there were physical traces like blood or bullet holes from the murders, it could potentially establish a physical loss, strengthening an argument for diminution in value, even if the cleanup cost itself is minimal. [ 10:28 ] - Real estate experts or appraisers could testify by comparing the home's value without the incident to similar properties affected by negative events. [ 13:04 ] - It's crucial to check your jurisdiction; while Georgia allows it, many states disallow it, and others have no specific case law on the matter. [ 14:00 ] - Tim provides a recap of the points above. Your PLRB Resources FAQ: Diminution in Value in First Party Property Claims - https://www.plrb.org/documents/diminution-in-value-in-first-party-property-claims/ Coverage Question: Pet Dog Attacked Owner; Blood on Carpet - https://www.plrb.org/documents/pet-dog-attacked-owner-blood-on-carpet-pcq-2023-10-27-twh-b/ Employees of member companies also have access to a searchable legal database, hundreds of hours of video trainings, building code materials, weather data, and even the ability to have your coverage questions answered by our team of attorneys (https://www.plrb.org/ask-plrb/) at no additional charge to you or your company. Subscribe to this Podcast Your Podcast App - Please subscribe and rate us on your favorite podcast app YouTube - Please like and subscribe at @plrb LinkedIN - Please follow at “Property and Liability Resource Bureau” Send us your Scenario! Please reach out to us at 630-509-8704 with your scenario! This could be your “adjuster story” sharing a situation from your claims experience, or a burning question you would like the team to answer. In any case, please omit any personal information as we will anonymize your story before we share. Just reach out to scenario@plrb.org.  Legal Information The views and opinions expressed in this resource are those of the individual speaker and not necessarily those of the Property & Liability Resource Bureau (PLRB), its membership, or any organization with which the presenter is employed or affiliated. The information, ideas, and opinions are presented as information only and not as legal advice or offers of representation. Individual policy language and state laws vary, and listeners should rely on guidance from their companies and counsel as appropriate. Music: “Piece of Future” by Keyframe_Audio. Pixabay. Pixabay License. Font: Metropolis by Chris Simpson. SIL OFL 1.1. Icons: FontAwesome (SIL OFL 1.1) and Noun Project (royalty-free licenses purchased via subscription). Sound Effects: Pixabay (Pixabay License) and Freesound.org (CC0).

Cut out at the end from Adamus Saint-Germain: https://www.youtube.com/watch?v=8TovZcWVl5g&list=WL&index=4 ➖➖➖➖➖➖➖➖➖➖➖➖➖YouTube English: https://www.youtube.com/Vegains YouTube DE: https://www.youtube.com/VegainsDE German Rap: https://www.youtube.com/@VegainsrapInstagram: https://www.instagram.com/vegainstrength Instagram DE: https://www.instagram.com/vegains/My DE Amazon: https://amazon.de/shop/vegainsde Listen to my podcast: https://anchor.fm/ferdibeckGerman podcast: https://anchor.fm/ferdibeckdeWebsite: https://www.vegansavage.com

Regresa de nuevo esta sección para traeros en esta ocasión los mejores Videojuegos de Mega Drive según algunos integrantes de nuestro programa. El menú de hoy: ✅ Nuestro TOP10 de SEGA Mega Drive Han participado: Rafa García (@rafagarvas) Gerard "Gepese" (@metalgerap) Alberto González "Gunkaiser" (@gunkaiser) Carlos Torres "Rode" (@rodeatope) Sergi Gurriz (@Waylis10) La voz del programa: Henar Hernández (@HenarHAsensio) Música de introducción: https://www.youtube.com/watch?v=fG2fgI4slBA&list=WL&index=2 Música de cierre: https://www.youtube.com/watch?v=VAVzJ5oPbc0&list=WL Síguenos: Web: http://www.gamelx.es Spotify: https://open.spotify.com/show/2O2RfgsZsopHhoUGzhjPx6 Apple Podcasts: http://itunes.apple.com/es/podcast/gamelx-fm/id573962600 Telegram: http://www.telegram.me/gamelx Twitter: @gamelx

The Bucs first OTAs of the offseason are underway! We discuss that, Haason Reddick's absence, Todd Bowle's recent comments on possible defensive changes, Lavonte/Gruden interview, and our 2025 W/L predictions!

Hemos tenido la oportunidad de analizar la nueva entrega de Doom y hemos querido aprovecharlo para traeros un programa especial sobre aquellos videojuegos en Primera Persona que tuvieron un gran impacto en la industria. Hazte voluntario en Juegaterapia: https://www.juegaterapia.org/colabora/ El menú de hoy: ✅ Efeméride de la semana ✅ Grandes juegos en Primera Persona ✅ Análisis de Doom: The Dark Ages Han participado: Alberto González "Gunkaiser" (@gunkaiser) Carlos Torres "Rode" (@rodeatope) Sergi Gurriz (@Waylis10) La voz del programa: Henar Hernández (@HenarHAsensio) Música de introducción: https://www.youtube.com/watch?v=fG2fgI4slBA&list=WL&index=2 Música de cierre: https://www.youtube.com/watch?v=VAVzJ5oPbc0&list=WL Síguenos: Web: http://www.gamelx.es Spotify: https://open.spotify.com/show/2O2RfgsZsopHhoUGzhjPx6 Apple Podcasts: http://itunes.apple.com/es/podcast/gamelx-fm/id573962600 Telegram: http://www.telegram.me/gamelx Twitter: @gamelx

Extended School Year (ESY) services can raise nuanced questions for IEP teams and special education professionals. On this episode of the Lozano Smith Podcast, host Aly R. Bivins talks with Roxana E. Khan and Erin Frazor about how ESY differs from summer school, the legal requirements under the IDEA, and how to make sound, individualized decisions. They round out the conversation by highlighting common pitfalls and offering practical tips to ensure compliance, including the importance of clear documentation. Show Notes & References 2:10 – ESY (Extended School Year services) vs. Summer School 2:52  – FAPE (Free Appropriate Public Education) and ESY 3:40 – Endrew F. v. Douglas County School District Re-1, 137 S. Ct. 988 (Client News Brief 12 - March 2017) 5:54 – Common ESY issues and questions 8:18 – How to determine eligibility for ESY 8:45 – Regression/Recoupment Analysis applied in California 10:14 – Three other standards determined by the courts 14:08 – What to provide during ESY 21:21 – When to make ESY determination 25:10 – Determining ESY eligibility for incoming students with less available information 28:01 – Litigation regarding ESY 34:17 – Does ESY only apply during the summer? 37:14 – Does the IDEA speak to Least Restrictive Environment (LRE) in relation to ESY? 38:45 – M.C. by & through S.B. v. Los Angeles Unified School District (C.D. Cal., Aug. 9, 2023) Case No. 2:20-CV-09127-CBM-E, 2023 WL 11066079 40:07 – Continuum of ESY placement options   For more information on the topics discussed in this podcast, please visit our website at: www.lozanosmith.com/podcast.

FOCUS 34 (SPONSOR VAN DEZE PODCAST)Deze uitzending wordt gesponsord door Focus34 van Rolf Nuyts en Priscilla Tielman.Focus34 organiseert m.b.v. de audiotechnologie Hemi-sync verschillende workshops en programma's. Je vindt alle informatie op www.focus34.comDaar kan je gratis een audio opname en of ebook downloaden.STEUN/SPONSOR DUTCH MATRIX : https://www.matrixboek.nl/doneren/BOEKEN EN KLEDING : https://www.matrixshop.nl/De meest cruciale aflevering ooit!In deze bijzondere aflevering komt alles samen wat we de afgelopen vijf jaar hebben behandeld. We duiken in de kern van de volgende onderwerpen: AI God: Hoe kunstmatige intelligentie onze realiteit beïnvloedt. Archonten: De verborgen krachten achter de schermen van onze wereld. Secret Space Program: De onthullingen rondom geheime ruimtevaartprogramma's. Kosmische Groepen & Families: Onze verbinding met buitenaardse en spirituele entiteiten.Alles lijkt zich nu af te spelen in een tijd waarin drones en UFO's wereldwijd massaal opduiken. De wereld lijkt in brand te staan, maar tegelijkertijd gebeurt er iets buitengewoon moois.Wat heeft de ontdekking van kwantumcomputers en AI te maken met de duivel?En hoe past Christus in dit grotere plaatje?Dit is een aflevering die je niet mag missen – misschien wel de belangrijkste ooit! Veel kijk- en luisterplezier!BRONNENVIDEO :KWANTUMCOMPUTER EN TIJDREIZENhttps://www.youtube.com/watch?v=0HG3ZaSAjI4&list=WL&index=4SENTIENT WORLD SIMULATIONhttps://www.youtube.com/watch?v=iEgZQgP9SMsMARTIJN VAN STAVEREN OVER SMARTPHONEShttps://www.youtube.com/watch?v=fb-F4hCoxcg&t=990sLuis Elizondo on Real UFO Encountershttps://www.youtube.com/watch?v=LvqUFdVicSEFARSIGHT REMOTE VIEWERShttps://www.youtube.com/watch?v=stKk4T6MrfsSTEUN/SPONSOR DUTCH MATRIX : https://www.matrixboek.nl/doneren/BOEKEN EN KLEDING : https://www.matrixshop.nl/

Traditionally, litigators seeking to understand an individual's or organization's devices - specifically, how they store, access, manage, and delete information - have either asked a deponent to testify from memory or arranged for a costly forensic inspection instead. In this episode, Jim spotlights a fantastic middle ground: requiring a deponent (individual or 30(b)(6) rep) to bring their devices to the deposition and demonstrate their functions and programs or apps during a videotaped examination. This technique was just approved by a federal judge in a pending class action against the ride-sharing company Uber. It's one all litigators should be using. As Jim says in the episode, devices are where information now lives. Lawyers should be more aggressive in their pursuit of discovery related to devices an individual or entity owns and how they access, store, manage, and delete data.SHOW NOTESIN RE: UBER TECHNOLOGIES, INC., PASSENGER SEXUAL ASSAULT LITIGATION, No. 23-MD-03084-CRB (LJC), 2025 WL 1393216 (N.D. Cal. May 14, 2025); See Joint Discovery Letter Brief on Plaintiff's 30(b)(6) deposition notice seeking device demonstration is Document 2957; Order Resolving Discovery Letter Regarding Rule 30(b)(6) Depositions is Document 2995.Section 9.43, Physical Demonstrations By Deponents, p. 357-359, in the book 10,000 Depositions Later - The Premier Litigation Guide For Superior Deposition Practice: A User's Guide and Handbook on Deposition Tips, Tactics and Strategies for Civil, Administrative and Arbitrative Litigation, 4th Edition, 615 pp., by Jim Garrity, Esq., available on Amazon and just about everywhere else books are sold.

DMan hosts Dollar Bank Extra Innings after the Guardians' close loss to the Cincinnati Reds. He also talks the updated NBA Playoff picture, as well as predicting the Browns' W/L ration this season.

In this episode, Rob & DT celebrate one of their favorite times of year as the '25 NFL schedule was released this week. The way the slate of games lays out for our Bills is giving the fellas straight #1 seed vibes as our Bills look to accomplish the last thing that has eluded them (regular season-wise) over the course of their most recent success.Rob thinks the way the marquee opponents are spread out over the 17 games is optimal for a really special regular season. With no international games or holiday games DT thinks the "consistency" of the schedule could lend itself to helping the Bills as they search for a 5th straight AFCE title and the playoffs that come thereafter. Make no mistake, there are still plenty of primetime matchups along with the 4:25pm window games that have now become like mini-primetime games within themselves.Rob sends out an official invitation to DT to come down to Charlotte when the Bills travel to play the Panthers. Rob thinks that game could mirror the 'Bills Takeover' games we've grown accustomed to seeing down in South Beach as CLT is littered with Mafia members!Finally, the fellas pick the W-L record for our '25 Bills and there is a consensus...our '25 Bills should be really really good this season.Become a supporter of this podcast: https://www.spreaker.com/podcast/nickel-city-crew-podcast--5347543/support.

In this episode, Rob & DT celebrate one of their favorite times of year as the '25 NFL schedule was released this week. The way the slate of games lays out for our Bills is giving the fellas straight #1 seed vibes as our Bills look to accomplish the last thing that has eluded them (regular season-wise) over the course of their most recent success. Rob thinks the way the marquee opponents are spread out over the 17 games is optimal for a really special regular season. With no international games or holiday games DT thinks the "consistency" of the schedule could lend itself to helping the Bills as they search for a 5th straight AFCE title and the playoffs that come thereafter. Make no mistake, there are still plenty of primetime matchups along with the 4:25pm window games that have now become like mini-primetime games within themselves. Rob sends out an official invitation to DT to come down to Charlotte when the Bills travel to play the Panthers. Rob thinks that game could mirror the 'Bills Takeover' games we've grown accustomed to seeing down in South Beach as CLT is littered with Mafia members!Finally, the fellas pick the W-L record for our '25 Bills and there is a consensus...our '25 Bills should be really really good this season.

Chiefs Schedule release, thoughts and opinions, Logan's predictions for the Chief's W/L, How will Mahomes respond to a down year statistically, Jackson Cantwell spotlight

Today I welcome Promod Sharma & Jeevan Sharma to the show to discuss the immediate financing arrangement (IFA).Promod (actuary) & Jeevan (CFP) specialize in helping high-net-worth individuals & tackling their unique situations beyond basic insurance coverage. Discussion Points:What is an IFA? (2:17)Whole life (WL) vs Universal life (UL) - which is more suitable for an IFA? (3:41)What is the cash surrender value (CSW)? (7:35)How can policies be structured to allow for IFAs...Important (9:30)Who could benefit from an IFA? (16:55)IFA mechanism: - policy as collateral (23:23)- how large can the loan be? (24:42)- lenders (26:32)- personal vs corporate loans (27:57)- loan rates (30:58)- guarantee fees (31:35)Does IFA impact policy growth? (33:34)Using policy as collateral vs directly borrowing from the policy (34:20)How are IFAs tax efficient? (36:34)Loophole? (42:34)Fees (44:55)Ways to pay off the loan (45:44)Permanent life & IFA checklist - Important (46:25)When not to pursue an IFA (50:56)IFA risks (53:09)--------------------------------------------------------------------------------------------------------------This episode features Arya EHR - https://www.aryaehr.com/**I endorse only products/services I personally use or would use. Any income generated offsets the costs of running this podcastPromod Sharma & Jeevan Sharma:https://taxevity.com/ps@taxevity.comjs@taxevity.comhttps://www.linkedin.com/in/promod/https://www.linkedin.com/in/jeevanksharma/Yatin Chadha:Email: beyondmdpodcast@gmail.com LinkedIn: Yatin Chadha

Rode ha vuelto de Japón y hoy nos trae un apasionante informe sobre uno de los viajes de su vida. Su recorrido, cultura, costumbres, anécdotas... El menú de hoy: ✅ Efeméride de la semana ✅ El viaje a Japón de Rode Han participado: Alberto González "Gunkaiser" (@gunkaiser) Carlos Torres "Rode" (@rodeatope) Sergi Gurriz (@Waylis10) La voz del programa: Henar Hernández (@HenarHAsensio) Música de introducción: https://www.youtube.com/watch?v=fG2fgI4slBA&list=WL&index=2 Música de cierre: https://www.youtube.com/watch?v=VAVzJ5oPbc0&list=WL Síguenos: Web: http://www.gamelx.es Spotify: https://open.spotify.com/show/2O2RfgsZsopHhoUGzhjPx6 Apple Podcasts: http://itunes.apple.com/es/podcast/gamelx-fm/id573962600 Telegram: http://www.telegram.me/gamelx Twitter: @gamelx

Today's episode showcases four new deposition-related rulings, including one that makes a compelling case for using Rule 31 depositions by written questions; a second that underscores the need to proactively consider limiting deposition transcript distribution; a third that highlights rare exceptions to a party's right to attend depositions; and a fourth which reinforces the basic principle that deposition subpoenas duces tecum cannot be used to shorten Rule 34's 30-day document production timeline. Thanks for listening, and be sure to check out the book on which this podcast is based, 10,000 Depositions Later: The Premier Litigation Guide for Superior Deposition Practice - A User's Guide and Handbook on Deposition Tips, Tactics & Strategies for Civil, Administrative, Arbitrative and Criminal Litigation. Available on Amazon and just about everywhere else books are sold.SHOW NOTESKilmetis v. Wal-Mart Stores East, LP, No. 24-CV-04452 (JMW), 2025 WL 1332056 (E.D.N.Y. May 7, 2025) (Rule 31 depositions)Hales v. Cook, et al., No. 1:24-cv45/ZCB, 2024 WL 5690279 (N. D. Fla. December 20, 2024) (on restricting distribution of deposition transcripts)Rupard, et al. v. County of San Diego, et al., No. 23-CV-1357 CAB (BLM), 2025 WL 1265858 (S. D. Cal. April 30, 2025) (on excluding parties from depositions in their own cases)Johnson v. Parks Floyd Investments, LLC, No. 2:23-cv-1063 SMD/KRS, 2025 WL 1191785 (D. New Mexico April 24, 2025) (on use of deposition subpoenas duces tecum to parties as a tool to circumvent and shorten the normal period for production of documents)

A windstorm-caused power outage at the Cheesecake Manufactory led to the spoilage of hundreds of cheesecakes and a business income loss. The adjuster is questioning if the windstorm deductible applies to the claim, despite the power outage being the direct cause of the spoilage.   Notable Timestamps [ 00:00 ] - The scenario presented involves a windstorm that caused a power outage, leading to spoiled cheesecakes and a claim for spoilage and lost business income, raising the central question of whether the windstorm deductible applies given the chain of events. [ 01:30 ] - Trivia: Where did the maximum natural wind gust ever recorded occur? [ 03:00 ] - The windstorm deductible endorsement states it applies to losses "caused directly or indirectly by windstorm or hail", but this language, even with "indirectly," can still lead courts to perform a proximate cause analysis, often leaving the "dominant and efficient cause" determination to a jury, unlike clearer anti-concurrent causation language. [ 04:30 ] - While "directly or indirectly" might address some indirect causation issues, the very definition of "windstorm" is not straightforward and is heavily subject to interpretation by courts based on specific case facts. [ 06:00 ] - Case law interpretations of "windstorm" can be narrow, such as a Rhode Island case finding high winds didn't qualify due to excessive rain; or surprising, like a Texas court holding a tornado was not a windstorm for deductible purposes. [ 07:30 ] - Is a tornado the epitome of a windstorm? Depends on who you ask... [ 09:00 ] - When two different endorsement provisions contain irreconcilable conflicts, such as both stating that "no other deductible applies" to the coverage they provide, a court might determine that no deductible applies at all. [ 12:00 ] - The business income claim follows a chain of events from the windstorm to the power outage and then the spoilage. The business income loss specifically results from the inability to operate due to the spoiled inventory, which might also involve potential Extra Expense. [ 13:30 ] - Brennan provides a recap of the scenario and the points above. Your PLRB Resources PLRB Catastrophe Services Launches New Power Outage Reports - https://www.plrb.org/documents/plrb-catastrophe-services-launches-new-power-outage-reports/?search=power%20outage%202025 Turner Construction Co. v. ACE Prop. & Cas. Ins. Co., No. 04-4451-CV, 2005 WL 2837575, — F.3d — (2d Cir. 10/28/05) (applying Texas law) reviewed at PLRB, Prop. Ins. L. Rev. 6978 (2005) Windstorm Deductible – Food Spoilage – BI – PCQ.2024.07.26.twh.a - https://www.plrb.org/documents/windstorm-deductible-food-spoilage-bi-pcq-2024-07-26-twh-a/?search=power%20outage%202024 Employees of member companies also have access to a searchable legal database, hundreds of hours of video trainings, building code materials, weather data, and even the ability to have your coverage questions answered by our team of attorneys (https://www.plrb.org/ask-plrb/) at no additional charge to you or your company. Subscribe to this Podcast Your Podcast App - Please subscribe and rate us on your favorite podcast app YouTube - Please like and subscribe at @plrb LinkedIN - Please follow at “Property and Liability Resource Bureau” Send us your Scenario! Please reach out to us at 630-509-8704 with your scenario! This could be your “adjuster story” sharing a situation from your claims experience, or a burning question you would like the team to answer. In any case, please omit any personal information as we will anonymize your story before we share. Just reach out to scenario@plrb.org.  Legal Information The views and opinions expressed in this resource are those of the individual speaker and not necessarily those of the Property & Liability Resource Bureau (PLRB), its membership, or any organization with which the presenter is employed or affiliated. The information, ideas, and opinions are presented as information only and not as legal advice or offers of representation. Individual policy language and state laws vary, and listeners should rely on guidance from their companies and counsel as appropriate. Music: “Piece of Future” by Keyframe_Audio. Pixabay. Pixabay License. Font: Metropolis by Chris Simpson. SIL OFL 1.1. Icons: FontAwesome (SIL OFL 1.1) and Noun Project (royalty-free licenses purchased via subscription). Sound Effects: Pixabay (Pixabay License) and Freesound.org (CC0).

Regresa un tema peliagudo al programa, pero es nuestra responsabilidad cubrir este tipo de actualidad sobre la Industria de los Videojuegos. Una industria que va de mal en peor en esta generación, y parece que solo un pequeño reducto de desarrolladoras están consiguiendo escapar de tanta volatilidad... El menú de hoy: ✅ Efeméride de la semana ✅ Los Videojuegos Doble A y el Estado de la Industria ✅ Análisis de Clair Obscure: Expedition 33 Han participado: Alberto González "Gunkaiser" (@gunkaiser) Gerard "Gepese" (@metalgerap) Rafa García (@rafagarvas) Sergi Gurriz (@Waylis10) La voz del programa: Henar Hernández (@HenarHAsensio) Música de introducción: https://www.youtube.com/watch?v=fG2fgI4slBA&list=WL&index=2 Música de cierre: https://www.youtube.com/watch?v=VAVzJ5oPbc0&list=WL Síguenos: Web: http://www.gamelx.es Spotify: https://open.spotify.com/show/2O2RfgsZsopHhoUGzhjPx6 Apple Podcasts: http://itunes.apple.com/es/podcast/gamelx-fm/id573962600 Telegram: http://www.telegram.me/gamelx Twitter: @gamelx

The Giants have gone 14-13 since their 8-1 explosive start. That doesn't sound amazing, but it's still good for the 4th best record in all of baseball. Unfortunately, the NL West has the two best teams in baseball with the Dodgers having won 8 of 9 games and the Padres have won 6 in a row. That said, the Giants are in the best shape at this point in the season since 2021. But...there are concerns. Many hitters are at or below .200. Their offense is average at best, and their starters are also around the average mark. So, why are they "overperforming?" Some of it has to do with their torrid start, but defense and other metrics creep in to alter a few losses to wins. Their expected W/L is only off by one. However, this could catch up in time. Chad and Willie discuss this and review the first quarter of the season and grade all facets of the Giants' game. We also go off on a tangent about Buster Posey's chances for the Hall of Fame in 2027...mostly inspired by Chad's recent visit to Cooperstown.www.torturecast.comfacebook.com/torturecast@torturecast

FOCUS 34 (SPONSOR VAN DEZE PODCAST)Deze uitzending wordt gesponsord door Focus34 van Rolf Nuyts en Priscilla Tielman.Focus34 organiseert m.b.v. de audiotechnologie Hemi-sync verschillende workshops en programma's. Je vindt alle informatie op focus34.com.Daar kan je gratis een audio opname en of ebook downloaden.Podcastomschrijving:In deze spannende aflevering deelt Nino zijn bizarre ervaring met een reptiliaans wezen en bespreekt hij hoe wij als mensen onze realiteit en toekomst kunnen beïnvloeden. Daarnaast duiken we in het mysterieuze drone-fenomeen in het noordoosten van de VS, waar honderden meldingen van gigantische, geruisloze drones de FBI en inwoners in paniek brengen. Is dit een veiligheidsrisico, een technologische doorbraak, of iets buitenaards? Kijk en ontdek de verrassende verbanden!NINO' S BOEK(EN) : booksareportals.comBRONNENhttps://www.youtube.com/watch?v=Nng6XquaXY0&list=WL&index=2&t=1016shttps://www.youtube.com/watch?v=KWPb_3L_-SE&list=WL&index=4https://www.youtube.com/watch?v=XvdK1ILJ9oo&list=WL&index=7&t=35s

First and foremost- IF YOU NEED HELP, PLEASE REACH OUT! THERE IS ALWAYS ANOTHER OPTION!!!Call 988 from any cellphone, or go to https://fightstory.org/ to get the support you need.You are loved.Welcome back, folks! We have officially survived the month-long slog that was #HangoverCardMarch, and are awaiting the return to Florida with open and eager arms! Even with all of the anticipation for #UFC314 this weekend, as is usually the case, they aren't the only punchykicky game in town. That being said, we'll still breakdown the in's and out's of it & all of the cards that you need to know about for this weekend as well as getting into all of the news that's come down the pipe since our last episode!As we SPRING back into Tapology action, don't miss out on the first tourney of the year over in our group, ImNoBookie! Join the group so you can be a part of the next tournament we have!If you can help us raise money to get kids in-need bikes for Easter to help our annual fundraiser, you can watch the livestream that Golftee hosted or find all of the links needed below. Fundraiser goes until the week before Easter, so there's time to assemble any bikes that need it.LiveStream- https://www.youtube.com/live/DhACx7U_IUYVenmo- https://venmo.com/u/jlpaskeAmazon Wishlist- https://www.amazon.com/hz/wishlist/ls/36B97JLHVMH9K?ref_=wl_shareWalmart WishList (Bikes)- https://www.walmart.com/registry/ER/47030e20-9c93-405d-9bbd-76a13845112bWalmart WishList (Other Needed Items)- https://www.walmart.com/lists/shared/WL/d61477a7-7dab-434a-88f3-e5949a108e72Our dear friend Ed has finished his battle. Please help us ease the burden on his wife MiMi to take care of his final arrangements.https://www.gofundme.com/f/edward-kapps-funeral-expenses#FuckCancerDon't forget about our Tapology Fight Picks! The group on Tapology.com (ImNoBookie or Group#965) is where we can make & compete with our picks for all major fights. The site keeps stats & will potentially let us compete head-to-head with each other AND YOU, the fans! Tune-in to find out how to join in on the fun! To honor our fallen friend Rye, please go watch the TMI episode we shot with him and leave some love. https://www.youtube.com/watch?v=2JkCWj1CuMA#RIPVapeRye #BeLikeRye Show Links- https://linktr.ee/imnojoeThe Crew's Socials- TJ: https://www.youtube.com/c/GolfTeeVapes & https://www.instagram.com/golfteevapes/Christian: https://www.instagram.com/slowbake_420/ The SlowBake & Contemplate Podcast: https://www.spreaker.com/show/slowbake-and-contemplate Meter Things: https://linktr.ee/TheMeterDoesManyThingsYou can also join our Patreon & help support the show here: https://www.patreon.com/ImNoJoePLEASE know that any and all donations are non-refundable, so make sure it's what you want to do before you click Send.That being said, I appreciate each and everyone who supports the me in ANY way, be it sharing a stream or donating, or even just hanging out in chat. Thank you to each and everyone who helps out. I appreciate you all.Be safe everyone! Wash your hands, and help someone just to do it.#StayHomeIfYoureSickComeOverIfYoureThicc ;)It shouldn't need to be said but apparently it does so I will- *ALL* music used on this channel is performed by and used with explicit permission from Adam Pilarczyk. There is a text disclaimer at the beginning of the show, and he is present in nearly every episode's live chat stating as much. THE MUSIC USED HERE DOES NOT INFRINGE UPON ANY COPYRIGHTS, AND FALSE CLAIMS AS SUCH WILL BE TREATED AS MALICIOUS!!!

Former MLB Pitcher Josh Towers and Scott Seidenberg discuss the latest stories around baseball with a look at the betting markets.

In this episode, Jim Garrity highlights three brand new deposition-related court rulings. The first presents the question of whether witnesses and their counsel can be prohibited from discussing the witnesses' testimony during recesses. The second addresses the propriety of asking foundational questions of privilege-bearing deponents to determine if the assertion of privilege is legitimate; the opinion explains what "foundational" questions are, gives examples, and details the procedure for deposing such witnesses and then presenting the issue to a court for decision. The third case in the spotlight highlights an avoidable problem when a lawyer seeks to depose an individual who has already testified in a 30(b)(6) capacity. Citations to the cases appear in today's show notes. Thanks for listening.SHOW NOTESVillareal v. Texas, Case No. 24-557, __ US __ (Apr. 7, 2025) agreeing to review ruling denying criminal defendant's request to confer about his testimony with his counsel during overnight breaks) petition for writ of certiorari at https://www.supremecourt.gov/DocketPDF/24/24-557/331695/20241113121417971_cert%20petition%20Villarreal%20v%20Texas.pdf; Brief in Opposition at https://www.supremecourt.gov/DocketPDF/24/24-557/348537/20250225093718236_250219a%20BIO%20for%20efiling.pdf; Reply Brief at https://www.supremecourt.gov/DocketPDF/24/24-557/351275/20250305130135816_cert%20reply%2024-557%20Villarreal%20v%20Texas.pdfAllergan, Inc. et al. v. Revance Therapeutics, Inc., No. 3:23-cv-00431, 2025 WL 1006372 (M. D. Tenn. Apr. 3, 2025) (outlining the procedure for questioning witnesses claiming privilege, and holding that foundational questions about the allegedly privileged communications must be allowed to determine whether a privilege exists)In re Social Media Adolescent Addiction/Personal Injury Products Liability Litigation, Case Number 22–MD–03047–YGR (PHK), 2025 WL 1009362 (N. D. Calif. Apr. 4, 2025) (denying request for deposition of a witness in an individual capacity, on basis that deposing party should have combined such a deposition with the 30(b)(6) deposition of the same person)

First and foremost- IF YOU NEED HELP, PLEASE REACH OUT! THERE IS ALWAYS ANOTHER OPTION!!!Call 988 from any cellphone, or go to https://fightstory.org/ to get the support you need.You are loved.Welcome back, folks! We are *FINALLY* at the end of the 4 week long suckfest of Fight Night #HangoverCards. Thankfully for us, as is usually the case, they aren't the only punchykicky game in town. That being said, we'll still breakdown the in's and out's of it & all of the cards that you need to know about for this weekend as well as getting into all of the news that's come down the pipe since our last episode!As we SPRING back into Tapology action, don't miss out on the first tourney of the year over in our group, ImNoBookie! Join the group so you can be a part of the next tournament we have!If you can help us raise money to get kids in-need bikes for Easter to help our annual fundraiser, you can watch the livestream that Golftee hosted or find all of the links needed below. Fundraiser goes until the week before Easter, so there's time to assemble any bikes that need it.LiveStream- https://www.youtube.com/live/DhACx7U_IUYVenmo- https://venmo.com/u/jlpaskeAmazon Wishlist- https://www.amazon.com/hz/wishlist/ls/36B97JLHVMH9K?ref_=wl_shareWalmart WishList (Bikes)- https://www.walmart.com/registry/ER/47030e20-9c93-405d-9bbd-76a13845112bWalmart WishList (Other Needed Items)- https://www.walmart.com/lists/shared/WL/d61477a7-7dab-434a-88f3-e5949a108e72Our dear friend Ed has finished his battle. Please help us ease the burden on his wife MiMi to take care of his final arrangements.https://www.gofundme.com/f/edward-kapps-funeral-expenses#FuckCancerDon't forget about our Tapology Fight Picks! The group on Tapology.com (ImNoBookie or Group#965) is where we can make & compete with our picks for all major fights. The site keeps stats & will potentially let us compete head-to-head with each other AND YOU, the fans! Tune-in to find out how to join in on the fun! To honor our fallen friend Rye, please go watch the TMI episode we shot with him and leave some love. https://www.youtube.com/watch?v=2JkCWj1CuMA#RIPVapeRye #BeLikeRye Show Links- https://linktr.ee/imnojoeThe Crew's Socials- TJ: https://www.youtube.com/c/GolfTeeVapes & https://www.instagram.com/golfteevapes/Christian: https://www.instagram.com/slowbake_420/ The SlowBake & Contemplate Podcast: https://www.spreaker.com/show/slowbake-and-contemplate Meter Things: https://linktr.ee/TheMeterDoesManyThingsYou can also join our Patreon & help support the show here: https://www.patreon.com/ImNoJoePLEASE know that any and all donations are non-refundable, so make sure it's what you want to do before you click Send.That being said, I appreciate each and everyone who supports the me in ANY way, be it sharing a stream or donating, or even just hanging out in chat. Thank you to each and everyone who helps out. I appreciate you all.Be safe everyone! Wash your hands, and help someone just to do it.#StayHomeIfYoureSickComeOverIfYoureThicc ;)It shouldn't need to be said but apparently it does so I will- *ALL* music used on this channel is performed by and used with explicit permission from Adam Pilarczyk. There is a text disclaimer at the beginning of the show, and he is present in nearly every episode's live chat stating as much. THE MUSIC USED HERE DOES NOT INFRINGE UPON ANY COPYRIGHTS, AND FALSE CLAIMS AS SUCH WILL BE TREATED AS MALICIOUS!!!

Bodyoids: Friend or Foe?   Patreon (Get ad-free episodes, Patreon Discord Access, and more!) https://www.patreon.com/user?u=18482113 PayPal Donation Link https://tinyurl.com/mrxe36ph MERCH STORE!!! https://tinyurl.com/y8zam4o2 Amazon Wish List https://www.amazon.com/hz/wishlist/ls/28CIOGSFRUXAD?ref_=wl_share Help Promote Dead Rabbit! Dual Flyer https://i.imgur.com/OhuoI2v.jpg "As Above" Flyer https://i.imgur.com/yobMtUp.jpg “Alien Flyer” By TVP VT U https://imgur.com/gallery/aPN1Fnw “QR Code Flyer” by Finn https://imgur.com/a/aYYUMAh Links: EP 1409 - The Forest Of Forever (Man Offers To Buy Child To Sell Organs story) https://deadrabbitradio.libsyn.com/ep-1409-the-forest-of-forever Ethically sourced “spare” human bodies could revolutionize medicine https://www.technologyreview.com/2025/03/25/1113611/ethically-sourced-spare-human-bodies-could-revolutionize-medicine/ OVER MY DEAD BODY ‘Spare' human bodies grown in artificial wombs in lab as scientists insist ‘bodyoids' feel no pain & can serve as ‘MEAT' https://www.the-sun.com/tech/13885342/spare-human-bodies-bodyoid-meat-grow-lab/ Synthetic human embryos created in groundbreaking advance https://www.theguardian.com/science/2023/jun/14/synthetic-human-embryos-created-in-groundbreaking-advance Does Chocolate Milk Contain Cow's Blood? https://www.snopes.com/fact-check/cow-blood-chocolate-milk/ „EYES OF THE DEVIL”. A DOCUMENTARY FILM BY PATRYK VEGA. https://www.youtube.com/watch?v=G1y38N4LQiU&list=WL&rco=1 Archive https://archive.org/details/the-eyes-of-the-devil SMALL WORLD Official Trailer (2021) https://www.youtube.com/watch?v=MrZX54Lz_hc   ------------------------------------------------ Logo Art By Ash Black Opening Song: "Atlantis Attacks" Closing Song: "Bella Royale" Music By Simple Rabbitron 3000 created by Eerbud Thanks to Chris K, Founder Of The Golden Rabbit Brigade Dead Rabbit Archivist Some Weirdo On Twitter AKA Jack YouTube Champ: Stewart Meatball Reddit Champ: TheLast747 The Haunted Mic Arm provided by Chyme Chili Discord Mods: Mason Forever Fluffle: Cantillions, Samson, Gregory Gilbertson, Jenny the Cat http://www.DeadRabbit.com Email: DeadRabbitRadio@gmail.com Facebook: www.Facebook.com/DeadRabbitRadio TikTok: https://www.tiktok.com/@deadrabbitradio Dead Rabbit Radio Subreddit: https://www.reddit.com/r/DeadRabbitRadio/ Paranormal News Subreddit: https://www.reddit.com/r/ParanormalNews/ Mailing Address Jason Carpenter PO Box 1363 Hood River, OR 97031 Paranormal, Conspiracy, and True Crime news as it happens! Jason Carpenter breaks the stories they'll be talking about tomorrow, assuming the world doesn't end today. All Contents Of This Podcast Copyright Jason Carpenter 2018 - 2025  

Howdy folks of the interwebs! Your host Double J is back with another edition of OpGCD Live!  Today, Double J is discuss'n "Manson Family" Style Murders: Parapolitics & the Idaho 4 case.In today's journey, your host Double J takes you Folks of the Interwebs on a journey of the HIGH-strangeness of "Manson Family" activity surround'n the Idaho 4 case!We are talk'n gruesome murders, drug traffick'n - notably the Process Church relative to the "Manson Family" murders, and of course the at minimum tertiary connects from the Idaho 4 murders and the murders of actress Sharon Tate and friends - courtesy of the "Manson Family" in the Hollywood hills of Los Angeles, CA in August 1969!Murders that shocked the general public & grasped the attention of millions - not unlike the Idaho 4 murders!This case against Bryan Kohberger for the murder of 4 young college students in their off campus home in Moscow ID/Univ of ID on Nov 13, 2022 has grasped the attention of folks worldwide!I suspect early on it was the brutal nature and rare occurrence of such horrendous murders - especially to 4 young adults who allegedly slept in their beds while attacked - at least that is what authorities wish the public to believe.Over time I suspect for many, like myself, that the apparent malfeasance and violations of protocol by law enforcement have caused that attention to remain on this case.However, it is law enforcement authorities' own actions and statements that have yielded the only reasonable conclusion in this case - that is Bryan Kohberger did NOT do it! Anyhow, folks of the interwebs, thank you again for joining me today to get a lil GCD! Enjoy today's podcast discussion on "Manson Family" Style Murders: Parapolitics & the Idaho 4 case!Enjoy the show! Links for JJ -https://linktr.ee/operationgcdID State Police Detective, Vickie Gooch interview - https://www.youtube.com/watch?v=QDKA8MlJmiI&list=WL&index=1&t=2938sGlobe article - https://www.pressreader.com/usa/globe/20221226/281741273455723?srsltid=AfmBOoqLJySpEhhYJqcSJ2rzMUUQlt_dzmCotrwhGGSXA0FJoUXclk8-

California Insurance Bulletin 2025-7 states the position that recent case law does not remove coverage for smoke damage claims. Bob Sallander is highly critical of the bulletin from the office of Insurance Commissioner Ricardo Lara, explaining that Bulletin 2025-7 misstates both Another Planet Entertainment, LLC v. Vigilant Insurance Company (Cal. Supreme Ct., 2024) 15 Cal.5th 1106 and Gharibian v. Wawanesa General Insurance Company (Cal. Ct. of Appeal, 2 nd Dist., Div. 2, 2025)2025 WL 426092. Join Bob Sallander for his summary of case law and how Bulletin 2025-7 is founded upon faulty logic. Have a topic you'd like Bob to cover? Submit it to questions@gpsllp.com, or connect with Bob directly on LinkedIn.And if you'd like to know more about GPSL, check out our website.You can also find us on LinkedIn, X, and Facebook.

The winter has been long and full of terrors. But it's finally over, as Orioles baseball is finally, mercifully back. After a promising 2024 season circled down the drain over several frustrating late summer months, and ended on as sour of a note as possible in another playoff sweep, what can the O's do to prove that was the exception to the otherwise promising rule that's been the post 2018 rebuild? The guys are here to get into all of that, starting with some recent news as we head towards the first pitch of the season on Thursday, including injury updates to Gunnar and Grayson, a familiar face rejoining the pitching staff, some final Spring Training analysis, and some upcoming Camden Yards changes to get excited for. They bookend the show with their official 2025 predictions, including W/L total, Team MVP, breakout player, and much more. Thanks as always for listening, and we'll be back at you very soon! This podcast is presented as always by Jimmy's Famous Seafood, who are here to get you ready for this baseball season in style with their annual TailGOAT being held on March 31st for the home opener! There's still plenty of time to get tickets to the party at https://tailgoat.com/product/opening-... starting at $60 general admission, but don't wait too long to grab them! Hosts: Jake Louque, Eric Arditti Producer: Jake Louque Thanks to our presenting sponsors, Jimmy's Seafood, Fed Thrill Sunglasses, Black Eyed Susan Spices, Clipper City Barber Co. Follow the show on social: Twitter: @Exit52Podcast, @JumboSetPodcast IG: exit52podcast TikTok: exit52podcast Music: "Soul Strut" by Taylor Fields (@EDCBurner)

On his first day back in office, President Trump issued Executive Order 14154 (Unleashing American Energy). Among numerous other objectives, this broad Executive Order directs the White House Council on Environmental Quality (CEQ) to “expedite and simplify the permitting process” by providing guidance on the implementation of the National Environmental Policy Act (NEPA) and rescinding CEQ’s NEPA regulations.Less than four weeks later, CEQ issued a Memorandum for Heads of Federal Departments and Agencies on how to conform their NEPA practices to the President’s Executive Order and other factors. Less than a week after that, CEQ published an interim final rule removing its NEPA regulations. Among the potential intended impacts of these actions is more expeditious federal government reviews of environmental permits. Even before these Executive Actions, courts had expressed concern over CEQ’s NEPA regulations. In November 2024, the D.C. Circuit held the CEQ regulations to be ultra vires. Marin Audubon v. FAA, 121 F.4th 902 (D.C. Cir. 2024)). In February 2025, the U.S. District Court for the District of North Dakota followed suit. Iowa v CEQ, No. 1:24-cv-00089-DMT-CRH, 2025 WL 598928 (D.N.D. Feb. 3, 2025).Join attorneys Mario Loyola and Ted Boling as they discuss these important developments in environmental law.Featuring:Ted Boling, Partner, Perkins Coie LLPMario Loyola, Senior Research Fellow, Environmental Policy and Regulation, Center for Energy, Climate, and Environment, The Heritage Foundation(Moderator) Garrett Kral, Administrative and Environmental Law Attorney

From Dracula on stage to voicing anime and video game legends, Daniel Van Thomas has done it all! In this episode, we dive into his work on Solo Leveling, Ultraman, and the Berserk short film, plus his passion for indie projects, convention stories, and so much more. If you love anime, voice acting, and behind-the-scenes stories, this one's for you!

Our roundup episodes summarize brand-new, deposition-related court rulings from around the country. We cover four new rulings in this episode on crucial issues:You can successfully oppose even otherwise taxable deposition costs, when an adversary prevails, by making these fairness-based argumentsFRCP 30(b)(6) topic lists must be proportionate to the case, as a court ruled when refusing to evaluate a list of 503 topicsThe rule of sequestration does not apply in federal civil cases and the majority of states, but you may succeed in getting a court to impose it if you can show one of these "plus" factorsIn-person depositions are still a thing, and should not be treated as unusual or requiring an extraordinary showingAs always, thanks for listening! And remember - these episodes are always free and contain no advertising. What's the catch? Only that we'd ask you to leave us a 5-star rating wherever you download your podcasts. Those ratings are deeply motivating to, and deeply appreciated by, our research and production staff. And be sure to check out the book on which this podcast is based - 10,000 Depositions Later: The Premier Litigation Guide for Superior Deposition Practice. Now in its 4th edition at 625 pages, available on Amazon and almost everywhere books are sold.SHOW NOTESLUV N' CARE v. LINDSEY LAURAIN, ET AL, No. CV 3:16-00777, 2025 WL 622334, at *8 (W.D. La. Feb. 26, 2025) (while courts cannot award costs not explicitly identified in 28 U.S.C. § 1920, courts do have discretion to deny award of otherwise recoverable costs where fairness or other considerations dictate)NATHEN W. BARTON, Plaintiff, v. REAL INNOVATION INC. et al., Defendant., No. 3:24-CV-05194-DGE, 2025 WL 606167, at *1 (W.D. Wash. Feb. 25, 2025) See 36-page notice (Case 3:24-cv-05194-DGE Document 51-1 Filed 01/14/25 Page 1 of 36 (contains 503 actual questions, not topics)MARK WRIGHT-AHERN, Plaintiff, v. THE CITY OF CLERMONT, Defendant., No. 5:24-CV-173-MMH-PRL, 2025 WL 605059, at *2 (M.D. Fla. Feb. 25, 2025) (rule of sequestration does not apply to depositions, absent particularized showing of specific facts warranting the relief; the correct procedure for seeking to exclude a person from deposition is to seek a protective order); see also Order (from same case, awarding fees and explaining sequestration concept in depositions), CM/ECF Document No. 31, filed Jan. 31, 2025)UNITED STATES OF AMERICA, Plaintiff, v. The M/Y Amadea, a Motor Yacht Bearing Int'l Mar. Org. No. 1012531, Defendant., No. 23 CIV. 9304 (DEH), 2025 WL 754124, at *1 (S.D.N.Y. Mar. 10, 2025) (ordering witness to travel overseas to United States for in-person deposition, finding that while remote depositions are the new normal, there remains nothing unusual about insisting that a key witness appear in person)

Here's a trap door to avoid: if you are trying to expedite an appeal by dismissing remaining claims, do not use the Judicial Council dismissal form. Instead, you need a judge-signed dismissal. While Jeff is still in trial, Tim covers Maniago v. Desert Cardiology Consultants' Medical Group, Inc. (Jan. 30, 2025, No. D085025) 2025 WL 617972. The plaintiff dismissed his remaining claims after his core theory was gutted on demurrer, but the Court of Appeal held that a voluntary dismissal using the Judicial Council form is not an appealable order.If you are an appellate specialist and trial counsel asks how to expedite an appeal after a devastating interlocutory ruling, you'll need to know about this trap door in Maniago, as well as the right way forward in Tos v. State (2021) 72 Cal.App.5th 184.And if you understand why a voluntary dismissal using the Judicial Council form is not appealable, but a voluntary dismissal using pleading paper is, then please volunteer to come on the podcast to explain it to the rest of us!Appellate Specialist Jeff Lewis' biography, LinkedIn profile, and Twitter feed.Appellate Specialist Tim Kowal's biography, LinkedIn profile, Twitter feed, and YouTube page.Sign up for Not To Be Published, Tim Kowal's weekly legal update, or view his blog of recent cases.Other items discussed in the episode:Maniago v. Desert Cardiology Consultants' Medical Group, Inc. (Jan. 30, 2025, No. D085025) 2025 WL 617972Tos v. State (2021) 72 Cal.App.5th 184Kurwa v. Kislinger (2017) 4 Cal.5th 109 (writeup here)

In this episode, Jim Garrity spotlights a new ruling on a little-known but powerful tool: the use of depositions as affidavits. As Garrity discusses, a deposition does not need to meet the requirements of trial-oriented Fed. R. Civ. P. 32 (which requires a showing that the party against whom the deposition is offered had notice and a chance to examine the deposition) when it is offered in proceedings that allow testimony by affidavit, such as at summary judgment.SHOW NOTESSurety v. Co. v. Dwight A. Herald, et al., Case No. 1:23-cv-00086-GNS-HBB, 2025 WL 627523 (W.D. Ky. Feb. 26, 2025) (deposition/examination under oath of witness taken in underlying state-court personal injury could be used in federal declaratory judgment actions at summary judgment time, as deposition meets form of affidavit)Diamonds Plus, Inc. v. Kolber, et al., 960 F. 2d 765 (8th Cir. 1992) (deposition need not be admissible at trial to be properly considered in opposition to motions for summary judgment; deposition inadmissible at trial because one of the defendants did not receive proper notice and did not attend the deposition was properly used to create issues of fact justifying denial of summary judgment)Hoover v. Switlik Parachute Co., 663 F.2d 964, 966-67 (9th Cir. 1981) (“Rule 56 ... plainly allows consideration of “affidavits” and we find nothing which requires that term to be construed within the limitations of Rule 32(a).”).First Gaston Bank of North Carolina v. City of Hickory, 691 S.E.2d 715 (Ct. App. N.C. 2010) (citing cases rejecting proposition that FRCP 32 limits use of depositions in proceedings where evidence in affidavit form is admissible; pointing out that to the extent a party objects that they didn't have an opportunity to cross-examine a witness whose deposition from some other cases being offered, “the same objection can frequently be made as to affidavits filed in connection with motions for summary judgment”)Tingey v. Radionics, 193 F. App'x 747, 765–66 (10th Cir. 2006) (reversing summary judgment where trial court, relying on FRCP 32, excluded from consideration in opposition to summary judgment a deposition that plaintiff took of physician in separate state proceeding, where defendant was not party to that proceeding and had not been given notice of deposition; depositions can be used as affidavits in proceedings where affidavits are admissible; to illustrate, “[p]arties may file affidavits in support of summary judgment without providing notice or an opportunity to cross-examine the affiant. See Fed.R.Civ.P. 56(c). The “remedy” for this non-confronted affidavit testimony is to file an opposing affidavit, not to complain that one was not present and permitted to cross-examine when the affidavit was signed. For this reason, the Ninth Circuit has permitted a party to introduce deposition testimony for summary judgment purposes against a party who was not present at the deposition, by construing the deposition as an affidavit. Hoover v. Switlik Parachute Co., 663 F.2d 964, 966–67 (9th Cir.1981)”)Nippon Credit Bank, Ltd. v. Matthews, 291 F.3d 738, 751 (11th Cir. 2002) (without analyzing scope and extent of application of FRCP 32, court broadly said that “Depositions are generally admissible provided that the party against whom they are admitted was present, represented, or reasonably noticed, Fed.R.Civ.P. 32(a), and are specifically allowed in consideration of summary judgment. Fed.R.Civ.P. 56(c). A deposition taken in a different proceeding is admissible if the party against whom it is offered was provided with an opportunity to examine the deponent. Fed.R.Evid. 804(b)(1).”)Fed. R. Civ. P. 56(c)(1)(A) (explicitly allowing citation to depositions for or against summary judgment)8 Charles Alan Wright & Arthur R. Miller, Federal Practice and Procedure § 2142 (1970))) (as are at least as good as affidavits and should be usable whenever an affidavit would be permissible, even where the conditions or requirements for use at trial under rule 32 are not met) 

A concert attendee filed suit against a band's lead singer based on the singer's alleged "onslaught" of blows to the attendee's face, head, and body over a dispute. However, the singer's claimed that the confrontation only became violent when the attendee threw the first punch.  Notable Timestamps [ 00:25 ] - The singer tendered the suit to his insurer, who agreed to defend under a reservation of rights, but is there a duty to defend? [ 01:25 ] - Seventies, eighties, nineties? The crew chats concerts. [ 02:30 ] - This scenario is based on New York Marine and General Ins. Co. v. Ness, 2021 WL 510624 (E.D. Cal. 1/12/21), linked below. [ 03:30 ] - "Four Corners" means looking only at the Complaint, and "Eight Corners" means looking at the insurance policy as well. Both phrases refer to ignoring outside evidence and focusing on the claims made for the purposes of determining the Duty to Defend. [ 04:30 ] - The court determined that the insured's claims raised a factual issue about the insured's intent. The exclusion for Expected or Intended Injury would not apply in cases of self-defense. [ 05:45 ] - The court found that when there are extrinsic facts from the insured, it is incorrect to assume that only the attendee's allegations matter, so they found a duty to defend. [ 06:15 ] - Courts might sometimes punish "creative pleading", but nevertheless often Complaints will include allegations of negligence, which in this case would have prevented a coverage dispute. [ 08:30 ] - States treat "extrinsic evidence rules" differently. Texas courts allow evidence that solely addresses coverage and does not contradict the facts in the Complaint. This scenario would fail the second prong. [ 09:45 ] - Florida would not permit an insurer to allege extrinsic evidence to dispute the duty to defend, whereas Hawaii or New York might. Some caselaw suggests that if an exclusion clearly applies, extrinsic evidence may be allowed. [ 12:20 ] - Expediency drives many of these rules, as well as insurers' decisions between Declaratory Judgment and denial. [ 13:20 ] - One South Carolina case required an insurer to look at extrinsic evidence. [ 14:30 ] - Can an insurer use an endorsement to permit the introduction of extrinsic evidence in disputes about the duty to defend? A Washington court has yet to answer this question in Developers Surety and Indemnity Co. v. Alis Homes, LLC, 2018 WL 1792182 (W.D. Wash. 4/16/18), reviewed at PLRB, Com. Liab. Ins. L. Rev. 5511 (2018). https://www.plrb.org/legacy-documents?DN=66854 [ 15:40 ] - A California case held that extrinsic evidence could establish a duty to defend-- that's this scenario, linked below. [ 17:35 ] - Michele provides a recap of the scenario and the points above. Your PLRB Resources On the admissibility of extrinsic evidence regarding an insurer's duty to defend, Commercial General Liability Policy Annotation Key GL37 - https://www.plrb.org/legacy-documents?DN=43173 Expected or intended injury exclusion, see Commercial General Liability Policy Annotation Key GL71 - https://www.plrb.org/legacy-documents?DN=43211 Law Review California Federal District Case - https://www.plrb.org/documents/new-york-marine-and-general-ins-co-v-ness/ Employees of member companies also have access to a searchable legal database, hundreds of hours of video trainings, building code materials, weather data, and even the ability to have your coverage questions answered by our team of attorneys (https://www.plrb.org/ask-plrb/) at no additional charge to you or your company. Subscribe to this Podcast Your Podcast App - Please subscribe and rate us on your favorite podcast app YouTube - Please like and subscribe at @plrb LinkedIN - Please follow at “Property and Liability Resource Bureau” Send us your Scenario! Please reach out to us with your scenario! This could be your “adjuster story” sharing a situation from your claims experience, or a burning question you would like the team to answer. In any case, please omit any personal information as we will anonymize your story before we share. Just reach out to scenario@plrb.org. Legal Information The views and opinions expressed in this resource are those of the individual speaker and not necessarily those of the Property & Liability Resource Bureau (PLRB), its membership, or any organization with which the presenter is employed or affiliated. The information, ideas, and opinions are presented as information only and not as legal advice or offers of representation. Individual policy language and state laws vary, and listeners should rely on guidance from their companies and counsel as appropriate. Music: “Piece of Future” by Keyframe_Audio. Pixabay. Pixabay License. Font: Metropolis by Chris Simpson. SIL OFL 1.1. Icons: FontAwesome (SIL OFL 1.1) and Noun Project (royalty-free licenses purchased via subscription). Sound Effects: Pixabay (Pixabay License) and Freesound.org (CC0).

When Christy channels the White Light, she is normally in the background. Sometimes, she goes completely out. But when it's just us, she can be fully present and talk to White Light like they're in the room with us. At the Orlando Retreat, she trued this for the entire group. We all sat around the couches and had a great conversation with WL. We like this format so much, we did a zoom call with everyone. Here's what happens when you just sit down and ask questions while Christy is completely present and aware.  Get the new Manifestation Event form here. Take the Life-Area perspective quiz.

In this episode, Dr. Seipp is joined by a cadre of students who have passed two Seal of Biliteracy assesments...an amazing accomplishment! He is also joined by Roxbury SS and WL supervisor, Matt Trokan who oversees the Seal of Biliteracy assessment program and has also passed two Seal of Billiteracy assessments. Being multi lingual is truly a superpower!

On February 6, Robert debated Judge Adam Tanenbaum (First DCA) about whether the prior-panel rule applies in the DCAs. The rule requires 3-judge appellate panels to follow prior-panel precedent unless the court overrules the prior precedent en banc or the precedent has been overruled by the Florida Supreme Court. Robert is a proponent of the rule, which he argues flows from Florida Rule of Appellate Procedure 9.331 (the en banc rule) and is supported by Florida Supreme Court precedent. Judge Tanenbaum is an opponent of the rule, which he argues has no basis in law and is contrary to article V, section 4(a) of Florida's Constitution. Robert co-authored an article in The Florida Bar Journal explaining his position. Judge Tanenbaum's position is best articulated in his concurring opinions in Normandy Ins. Co. v. Bouayad, 372 So. 3d 671 (Fla. 1st DCA 2023) (en banc), review granted, No. SC2023-1576, 2024 WL 4449458 (Fla. Oct. 9, 2024) and BAM Trading Servs. Inc. v. Off. of Fin. Regul., 395 So. 3d 687 (Fla. 1st DCA 2024) (en banc).Thanks to the Hillsborough County Bar Association for hosting the event and to David Costello of the Florida Office of the Attorney General and Dimitri Peteves of Creed and Gowdy P.A. for an amazing job organizing and moderating the debate.  Please send your questions, comments, and feedback to summarilypod@gmail.com.Disclaimer: This podcast is for informational purposes only and is not an advertisement for legal services.  The information provided on this podcast is not intended to be legal advice.  You should not rely on what you hear on this podcast as legal advice. If you have a legal issue, please contact a lawyer.  The views and opinion expressed by the hosts and guests are solely those of the individuals and do not represent the views or opinions of the firms or organizations with which they are affiliated or the views or opinions of this podcast's advertisers.  This podcast is available for private, non-commercial use only.  Any editing, reproduction, or redistribution of this podcast for commercial use or monetary gain without the expressed, written consent of the podcast's creator is prohibited.

How do you get alumni to actually engage? It's the million-dollar question for higher ed advancement teams—and today, we've got answers. In this week's episode, Ryan Catherwood, Senior Vice President at Chris Marshall Advancement Consulting (CMAC), Senior Consultant at Washburn & McGoldrick, and host of the Alumless podcast joins Dustin to break down the evolving landscape of digital alumni engagement.Ryan brings decades of experience in alumni relations, fundraising strategy, and digital marketing, and he shares insights on what works, what doesn't, and what's next. From the shifting role of social media to the power of email (yes, email!), and the reality check on alumni platforms, this conversation is packed with actionable takeaways.Guest Name: Ryan Catherwood - Executive Vice President and Senior Consultant, Chris Marshall Advancement ConsultingGuest Social: LinkedInGuest Bio: Ryan Catherwood currently serves as Executive Vice President and Senior Consultant at CMAC, and consulting partner with Washburn & McGoldrick LLC. Ryan specializes in engagement strategies for volunteer and donor pipeline development that are rooted in a digitally focused, content-based approach to advancement in support of education.Before joining CMAC, Ryan led the Office of Alumni & Career Services at Longwood University. His early leadership roles in advancement included marketing and digital engagement responsibilities at the University of Virginia and W&L. - - - -Connect With Our Host:Dustin Ramsdellhttps://www.linkedin.com/in/dustinramsdell/About The Enrollify Podcast Network:The Higher Ed Geek is a part of the Enrollify Podcast Network. If you like this podcast, chances are you'll like other Enrollify shows too!Enrollify is made possible by Element451 — the next-generation AI student engagement platform helping institutions create meaningful and personalized interactions with students. Learn more at element451.com.Attend the 2025 Engage Summit! The Engage Summit is the premier conference for forward-thinking leaders and practitioners dedicated to exploring the transformative power of AI in education. Explore the strategies and tools to step into the next generation of student engagement, supercharged by AI. You'll leave ready to deliver the most personalized digital engagement experience every step of the way.Register now to secure your spot in Charlotte, NC, on June 24-25, 2025! Early bird registration ends February 1st -- https://engage.element451.com/register

Lots of people think that video games are a waste of time. Well, that may depend on how they're used and what games are being played. In this episode, we examine many of the health benefits that can be derived from a healthy video game diet. Playing games can lead to the acquisition of a surprisingly large number of skills. Skills that your parents probably weren't aware of, or that they didn't realize where you learned them. Bottom line is: games are dope. You should play them. Let us know what talents and skills you've gained through playing certain games in the comments! Thanks for watching and being part of the conversation. **We're Now On Spotify**: https://open.spotify.com/show/4gIzzvT3AfRHjGlfF8kFW3 **Listen On Soundcloud**: https://soundcloud.com/resonantarc **Listen On iTunes**: https://podcasts.apple.com/us/podcast/state-of-the-arc-podcast/id1121795837 **Listen On Pocket Cast**: http://pca.st/NJsJ Patreon Page: https://www.patreon.com/resonantarc Subscribe Star: https://www.subscribestar.com/resonant-arc Twitter: https://twitter.com/resonantarc Facebook: https://www.facebook.com/resonantarc Instagram: https://www.instagram.com/resonantarc TikTok: https://www.tiktok.com/@resonantarc Research links: https://files.eric.ed.gov/fulltext/EJ1304728.pdf https://scientificorigin.com/15-surprising-benefits-of-playing-video-games https://www.apa.org/pubs/journals/releases/amp-a0034857.pdf https://journals.plos.org/plosone/article?id=10.1371%2Fjournal.pone.0120011 https://journals.plos.org/plosone/article?id=10.1371%2Fjournal.pone.0187779 https://www.cnn.com/2022/10/24/health/kids-video-games-cognition-memory/index.html https://www.videogameseurope.eu/perspective/girls-who-play-video-games-are-three-times-more-likely-to-pursue-stem-careers-than-girls-who-dont/ https://education.minecraft.net/en-us/blog/teaching-sel-and-cs-with-intention https://www.youtube.com/watch?v=twE-zdUkB_U&list=WL&index=1 https://www.gse.harvard.edu/ideas/usable-knowledge/21/06/find-fun https://today.tamu.edu/2021/09/06/5-reasons-video-games-should-be-more-widely-used-in-school/ https://www.sciencedirect.com/science/article/abs/pii/S1359178907000055 https://www.sciencedirect.com/science/article/abs/pii/S0747563212000623 https://www.washingtonpost.com/news/worldviews/wp/2012/12/17/ten-country-comparison-suggests-theres-little-or-no-link-between-video-games-and-gun-murders/ https://www.forbes.com/sites/erikkain/2012/04/19/as-video-game-sales-climb-year-over-year-violent-crime-continues-to-fall/ https://www.youtube.com/watch?v=xaICKlp9kQc https://www.forbes.com/sites/daviddisalvo/2014/04/06/the-surprising-connection-between-playing-video-games-and-a-thicker-brain/#:~:text=What%20they%20found%20is%20that,brain's%20command%20and%20control%20center https://news.byu.edu/news/video-games-are-good-girls-if-parents-play-along#:~:text=Researchers%20from%20Brigham%20Young%20University's,family%20connection%2C%20mental%20health

The Bulls made a big move last night, trading Zach LaVine to the Sacramento Kings. Bulls fans hold mix reviews of the trade, which has CHGO White Sox host, Sean Anderson wondering, will Luis Robert Jr. hold a similar fate? Plus, PECOTA projects the Sox to win 62 games! Can the Sox improve their W-L record by 20 games?

In this episode, Jim Garrity talks about a tactic of some examining lawyers that should, but often doesn't, draw objections that their questions are “argumentative.” So, what is an improper, argumentative question or examination? Here, we're not talking about the questioner's tone or demeanor, i.e., arguing in the classic sense of yelling and bickering with the deponent. We're talking about questions where lawyers aren't really asking a question designed to elicit facts but are instead injecting their own commentary or viewpoint, or injecting insults, taunts, wisecracks, or similar language. "Argumentative" objections are objections to the form, and must be timely made or are waived.SHOW NOTESPeople v. Pawar, No. G037097, 2007 WL 477949, at *2 (Cal. Ct. App. Feb. 15, 2007) (“[W]ere they lying” queries are improper if they are merely argumentative. (Chatman, supra, 38 Cal.4th at pp. 381, 384.) In Chatman, the prosecutor asked the defendant how the safe at a store was opened. (Id. at p. 379.) The defendant replied “he could not say; he never touched the safe,” eliciting the prosecutor's query, “ ‘Well, is the safe lying about you?' “ (Ibid.) The Supreme Court held the question of whether an inanimate object was “lying” was argumentative , defining argumentative inquiry as “speech to the jury masquerading as a question” which “does not seek to elicit relevant, competent testimony, or often any testimony at all.” (Id. at p. 384.))Faile v. Zarich, No. HHDX04CV5015994S, 2008 WL 2967045, at *3 (Conn. Super. Ct. July 10, 2008) (Webster's. . . in the closest relevant definition, defines “argumentative” as “consisting of or characterized by argument: containing a process of reasoning: controversial”)Pardee v. State, No. 06-11-00226-CR, 2012 WL 3516485, at *6 (Tex. App. Aug. 16, 2012) (Steven Goode, et al., Texas Practice Series: Courtroom Handbook on Texas Evidence § 611 cmt. 12 (2012); see United States v. Yakobowicz, 427 F.3d 144, 151 (2d Cir.N.Y.2005) (defining argumentative as “summation-like remarks by counsel during the presentation of evidence”); accord Eddlemon v. State, 591 S.W.2d 847, 851 (Tex.Crim.App. [Panel Op.] 1979) (trial court did not abuse discretion in finding the question, “You don't believe your own offense report?” argumentative). In other words, an argumentative objection concerns whether counsel is attempting to “argue” the case, not whether the counsel is “arguing” with the witness”)United States v. Yakobowicz, 427 F.3d 144, 151 (2d Cir. 2005) (“During the presentation of evidence one of the most commonly sustained objections is that a particular question is argumentative, Fed.R.Evid. 611(a) advisory committee's note to Subdivision (a) to 1972 Proposed Rules, and any summation-like remarks by counsel during the presentation of evidence are improper and subject as a routine matter to being stricken, Mauet & Wolfson, supra, at 30”)Pardee v. State, No. 06-11-00226-CR, 2012 WL 3516485, at *6 (Tex. App. Aug. 16, 2012) ("Many common law objections—including the objection of “argumentative”—are incorporated in the Texas Rules of Evidence. The common law argumentative objection is now governed by Tex.R. Evid. 611 which concerns the mode of interrogation and presentation. The argumentative objection is an objection commonly used, but not commonly understood. Pardee argues the objection should have been sustained because the State was “arguing” with the defendant. Argumentative, though, does not concern counsel's demeanor or tone. Professors Wellborn, Goode, and Sharlot explain the argumentative objection as follows: Counsel may not, in the guise of asking a question, make a jury argument or attempt to summarize, draw inferences from, or comment on the evidence. In addition, questions that ask a witness to testify as to his own credibility are improper.")People v. Chatman, 38 Cal. 4th 344, 384, 133 P.3d 534, 563 (2006) The prosecutor's question about whether the safe was “lying” requires a different analysis. The question was argumentative. An argumentative question is a speech to the jury masquerading as a question. The questioner is not seeking to elicit relevant testimony. Often it is apparent that the questioner does not even expect an answer. The question may, indeed, be unanswerable. The prosecutor's question whether “the safe [was] lying” is an example. An inanimate object cannot “lie.” Professor Wigmore has called cross-examination the “greatest legal engine ever invented for the discovery of truth.” (5 Wigmore on Evidence (Chadbourne rev. ed.1974) § 1367, p. 32.) The engine should be allowed to run, but it cannot be allowed to run amok. An argumentative question that essentially talks past the witness, and makes an argument to the jury, is improper because it does not seek to elicit relevant, competent testimony, or often any testimony at all. Defendant had already explained he had no explanation for the safe being open. Asking whether the safe was “lying” could add nothing to this testimony”)People v. Imbach, No. E040190, 2008 WL 510482, at *7–8 (Cal. Ct. App. Feb. 27, 2008) ("The prosecutor asked, “You found that to be inappropriate but not your other son's addiction to child pornography?” When defendant objected that the question was argumentative, the trial court overruled that objection. Defendant asserted the second “argumentative” objection when defendant's mother said she did not know how to answer that question and the prosecutor asked, “Is that because you didn't want to know?” The trial court sustained the defendant's objection to this second question. Both questions are argumentative, because they both are speeches by the prosecutor masquerading as questions. (Chatman, supra, 38 Cal.4th at p. 384.) The trial court should have sustained both objections. However, we cannot say that by asking those two questions the prosecutor engaged in misconduct.")People v. Peoples, 62 Cal. 4th 718, 793–94, 365 P.3d 230, 288 (2016) (“Defendant observes that the prosecutor asked numerous argumentative questions when cross-examining defense witnesses. To list a few examples, the prosecutor asked defense expert Dr. Lisak, “how many hours are you into them for?” He said to defense expert Dr. Buchsbaum, “Let's quit guessing for awhile and look at the facts.” He said to defense expert Dr. Wu, “It's a pain in the butt to get these test scores.” And he asked prosecution expert Dr. Mayberg, “Did you have a heart attack last night when you looked at the raw data?”)People v. Burns, No. D081051, 2024 WL 2144151, at *15–17 (Cal. Ct. App. May 14, 2024), review denied (July 17, 2024) (excessive repetition of a question simply to make a point can cross line into improper argument”; “Burns makes a strong argument that the prosecutor's repetitive questioning regarding the drunk tank incident became argumentative. “An argumentative question is a speech to the jury masquerading as a question. The questioner is not seeking to elicit relevant testimony. Often it is apparent that the questioner does not even expect an answer. The question may, indeed, be unanswerable.” (People v. Chatman (2006) 38 Cal.4th 344, 384.) “An argumentative question that essentially talks past the witness, and makes an argument to the jury, is improper because it does not seek to elicit relevant, competent testimony, or often any testimony at all.” (Ibid.) Instead, it may be aimed at agitating or belittling the witness (People v. Lund (2021) 64 Cal.App.5th 1119, 1148), or designed to engage the witness in an argument (People v. Johnson (2003) 109 Cal.App.4th 1230, 1236)”)People v. Mazen, No. B300193, 2021 WL 164356, at *5 (Cal. Ct. App. Jan. 19, 2021) The court overruled defendant's argumentative objection to the following question: “Would [accidentally placing the car in neutral] been important information to tell [Morales]?” The court did not abuse its discretion when it overruled the objection. The question sought to elicit relevant testimony regarding defendant's theory that Mario was hit by accident (CALCRIM No. 510). (See People v. Chatman (2006) 38 Cal.4th 344, 384 [“[a]n argumentative question is a speech to the jury masquerading as a question” and does not seek to elicit relevant testimony].)”People v. Singh, No. H042511, 2018 WL 1046260, at *28 (Cal. Ct. App. Feb. 26, 2018) (“Each question anticipated an answer and was answerable; none was “a speech to the jury masquerading as a question”)People v. Basler, No. D068047, 2015 WL 9437926, at *23 (Cal. Ct. App. Dec. 23, 2015) ("Fung appears to identify three categories of objectionable questioning during his cross-examination by the prosecutor. The first category involves apparent sarcasm by the prosecutor. For example, after Fung provided additional details about his fight with another inmate while incarcerated, the prosecutor said, “Okay. You left that part out a couple of minutes ago; right?” Referencing the same fight, the prosecutor made light of Fung's claim of self-defense: “Did you have to defend yourself against him, too?” As another example, when Fung was discussing the extent of his injuries following the fight, the prosecutor said, “So, that's about how badly you were hurt? It looked like something you get by falling off a skateboard?” The court sustained objections to each of these questions, and a number of others, as argumentative." Also from Basler: "As we have noted, Fung contends the first two categories of questions were impermissibly argumentative. “An argumentative question is a speech to the jury masquerading as a question. The questioner is not seeking to elicit relevant testimony. Often it is apparent that the questioner does not even want an answer. The question may, indeed, be unanswerable.... An argumentative question that essentially talks past the witness, and makes an argument to the jury, is improper because it does not seek to elicit relevant, competent testimony, or often any testimony at all.” (People v. Chatman (2006)”)People v. Nanez, No. F064574, 2014 WL 1928307, at *14–15 (Cal. Ct. App. May 15, 2014) (citing examples of argumentative examination by prosecutor including (a) the prosecutor's remark “Convenient” when a witness said they did not remember a particular fact, and (b) when prosecutor commented on witnesses testimony by saying “So that's the lie you're going with?”, and (c) when prosecutor asked witness “You wouldn't tell us if you're lying, of course, right?” and when witness said he would, prosecutor replied “There's another lie,” causing court to strike prosecutor's comment from the record)People v. Strebe, No. D057947, 2011 WL 2555653, at *7 (Cal. Ct. App. June 28, 2011) (trial courses sustained objection to question as argumentative where prosecutor asked witness “Do you remember anything about that evening that might be detrimental to your case?” In essence arguing to jury that witness was lying and only selectively remembered favorable facts)People v. Higgins, 119 Cal. Rptr. 3d 856, 873–74 (Ct. App. 2011), as modified (Jan. 21, 2011), as modified on denial of reh'g (Feb. 4, 2011) (guilty verdict reversed in part due to argumentative questions; among other jabs; in case where defendant explained his conduct as motived by depression due to death of his daughter's friend, prosecutor asked, “You'd agree with me that it's pretty pathetic if you're using the memory of a dead 17–year–old kid as an excuse in this trial, wouldn't you? Would you agree with me? Is that the legacy that you want [the dead teen] to have?”; other examples of prosecutor's argumentative questions included “Oh, the door was unlocked,” and “Isn't that convenient that all of a sudden, right after you've committed the crimes, that that's when you come to?”; further held, “The rule is well established that the prosecuting attorney may not interrogate witnesses solely ‘for the purpose of getting before the jury the facts inferred therein, together with the insinuations and suggestions they inevitably contained, rather than for the answers”)People v. Dixon, No. D047342, 2007 WL 2745207, at *10 (Cal. Ct. App. Sept. 21, 2007)  Dixon asked Hernandez who had taken the photographs near the time of the injury. Hernandez testified that the audio-visual person at his school had taken photographs of his injury. Dixon then asked, “Is it computer enhancement? Those could be computer enhanced-.” The prosecutor interrupted, “That's argumentative.” The court sustained the prosecutor's objection")United States v. Browne, No. SACR 16-00139-CJC, 2017 WL 1496912, at *6 (C.D. Cal. Apr. 24, 2017) (For each witness, the Court did not end Defense counsel's cross-examination until it became excessively cumulative and argumentative, at which time the Court was well within its authority to restrain the questioning pursuant to Federal Rule of Evidence 611(a).”)Beving v. Union Pac. R.R. Co., No. 3:18-CV-00040, 2020 WL 6051598, at *12 (S.D. Iowa Sept. 8, 2020) (Defendant may object to prejudicial or argumentative references to counsel at trial as permitted by the Federal Rules of Evidence. See Fed. Rs. Evid. 403, 611(a)(3).)FRE 403: Argumentative questions may be viewed as unfairly prejudicial, misleading, or wasting time.FRE 611(a)(3), Witnesses and Presenting Evidence ((a) Control by the Court; Purposes. The court should exercise reasonable control over the mode and order of examining witnesses and presenting evidence so as to: (1) make those procedures effective for determining the truth; (2) avoid wasting time; and (3) protect witnesses from harassment or undue embarrassment.FRCP 30, Depositions, (d) Duration; Sanction; Motion to Terminate or Limit. (3) Motion to Terminate or Limit, (A) Grounds. At any time during a deposition, the deponent or a party may move to terminate or limit it on the ground that it is being conducted in bad faith or in a manner that unreasonably annoys, embarrasses, or oppresses the deponent or party. 

I'm not a financial advisor; Superpowers for Good should not be considered investment advice. Seek counsel before making investment decisions.Watch the show on television by downloading the e360tv channel app to your Roku, AppleTV or AmazonFireTV. You can also see it on YouTube.When you purchase an item, launch a campaign or create an investment account after clicking a link here, we may earn a fee. Engage to support our work.Has your business been impacted by the recent fires? Apply now for a chance to receive one of 10 free tickets to SuperCrowdLA on May 2nd and 3rd and gain the tools to rebuild and grow!Devin: What is your superpower?Robert: I think, ultimately, it is my passion for this topic. Growing up here in Portland, I'm infused with the principles of sustainability and environmental stewardship. I'm grateful to have grown up in this community where those values are front and center. Portland has a great history of urban planning, of really trying to do smart growth. I remember, as a kid, growing up, sorting out recycling, going out for hikes and camping. The reverence for nature and the planet is very, very deep. That's why I got into real estate development in the first place in college, recognizing the potential power of the industry to have a positive impact in this way.In today's world, sustainability is no longer optional—it's essential. Robert Pile, Founder of Oakleaf reDevelopment, has taken this challenge head-on with an innovative net-zero housing project in Portland. His 12-unit development in the St. John's neighborhood is a shining example of what's possible when environmental stewardship and urban planning align.At the heart of this project is the commitment to net zero energy use. As Robert explained, “The secret recipe is really in the proportions of the building… a super-tight envelope, high-efficiency HVAC systems, and rooftop solar panels.” These elements work together to ensure the building generates as much energy as it consumes.Such innovation doesn't come without challenges. With only a limited roof area for solar panels, the design had to be meticulously planned. Still, Robert remains optimistic, highlighting that their calculations are on target. “Our energy modeling… is right on the money in terms of the projected energy use and generation from the roof,” he said.Importantly, this project is about more than sustainability. It also addresses Portland's growing housing needs. Leveraging a zoning change from 2020, the development densifies the urban core while staying in harmony with environmental goals. By focusing on urban infill, Oakleaf reDevelopment is creating a model that could be replicated across the city to provide more housing while reducing the community's carbon footprint.Robert's vision extends beyond this project. “The opportunity we have is to leverage the outsized impact of the building industry… by pursuing more sustainable, energy-efficient, and net zero types of projects,” he noted. His passion for combining business with sustainability reflects a larger movement toward responsible development.If you're as inspired as I am, you can learn more about the project and even invest in it through a regulated crowdfunding campaign on Small Change. With this approach, Robert is not just building housing but also inviting the community to be a part of the solution. Visit s4g.biz/WL to explore the opportunity to make a difference and a profit.Robert's work is a testament to the power of innovative thinking and collaboration in addressing the climate crisis. It's proof that when we combine technology, passion, and community, we can build a better future—literally.tl;dr:* Robert Pile explains Oakleaf reDevelopment's innovative net zero housing project in Portland.* The project combines urban infill and sustainability, reducing energy use with efficient designs.* Robert highlights how zoning changes enabled this eco-friendly, scalable development model.* He shares his passion for sustainability and the formative experiences shaping his vision.* Robert advises engaging with nature and supporting sustainable businesses to amplify environmental impact.How to Develop Environmental Passion As a SuperpowerRobert Pile's superpower is his unwavering passion for sustainability. Growing up in Portland, he was immersed in values of environmental stewardship, which shaped his life and career. As he put it, “The built environment uses disproportionate amounts of energy… the opportunity to pursue more sustainable, energy-efficient, and net zero projects excites me the most.”One memorable story illustrates his connection to nature: Robert recalls growing up in Portland, where his family's activities often revolved around the outdoors. Whether hiking or recycling, these moments laid the foundation for his environmental ethic and his desire to make a difference through sustainable real estate development.Robert offers practical advice for developing this superpower:* Spend time in nature to foster a personal connection with the environment.* Support sustainability-focused businesses and initiatives.* Be mindful of consumption by choosing local products and services.* Leverage financial resources to contribute to environmental causes.By following Robert's example and advice, you can make environmental passion a skill. With practice and effort, you could make it a superpower that enables you to do more good in the world.Remember, however, that research into success suggests that building on your own superpowers is more important than creating new ones or overcoming weaknesses. You do you!Guest ProfileRobert Pile (he/him):Founder, Oakleaf reDevelopmentAbout Oakleaf reDevelopment: Portland-based sustainability-centered multifamily housing provider.Website: www.oakleaf.devOther URL: smallchange.co/projects/West-LombardBiographical Information: Robert Pile grew up in Milwaukie, OR and attended La Salle High School before going to the University of San Diego, where he earned a Bachelor's Degree in Economics, Real Estate. He then returned to Portland and started working for TMT Development as an Associate Property Manager in 2006. Over the 13 years he was with TMT, he also served as the Director of Operations, Associate Vice President, COO, and Executive Vice President, Development and Construction. In 2014, he received a Master's Degree in Real Estate Development from Portland State University. His major professional accomplishments include managing more than a million square feet of Class A office, retail, and residential space; executing millions of dollars in Class A office and retail Tenant Improvements; co-managing the construction of a major mixed-use high rise in downtown Portland; and managing the development and construction of a 59-unit mixed-use residential/retail project in SE Portland. Robert is a Certified Construction Manager (CCM) and an Oregon Principal Broker. He's also an active member of the Oregon chapter of NAIOP and serves on the Public Affairs committee.Linkedin: linkedin.com/in/robertlpile/Support Our SponsorsOur generous sponsors make our work possible, serving impact investors, social entrepreneurs, community builders and diverse founders. Today's advertisers include FundingHope, Belleview Montgomery, Crowdfunding Made Simple and SuperCrowd Impact Membership. Learn more about advertising with us here.Max-Impact MembersThe following Max-Impact Members provide valuable financial support:Carol Fineagan, Independent Consultant | Lory Moore, Lory Moore Law | Marcia Brinton, High Desert Gear | Paul Lovejoy, Stakeholder Enterprise | Pearl Wright, Global Changemaker | Ralf Mandt, Next Pitch | Scott Thorpe, Philanthropist | Add Your Name HereUpcoming SuperCrowd Event CalendarIf a location is not noted, the events below are virtual.* Impact Cherub Club Meeting hosted by The Super Crowd, Inc., a public benefit corporation, on January 21, 2024, at 1:00 PM Eastern. Each month, the Club meets to review new offerings for investment consideration and to conduct due diligence on previously screened deals. To join the Impact Cherub Club, become an Impact Member of the SuperCrowd.* SuperCrowdHour, February 19, 2025, at 1:00 PM Eastern. Devin Thorpe will be leading a session on "Calculating Your Funding Needs," providing essential guidance for entrepreneurs and impact-driven businesses to determine the right amount to raise for sustainable growth. Whether you're preparing for your first crowdfunding campaign or planning to scale, this is a must-attend! Don't miss it!* SuperCrowdLA: we're going to be live in Santa Monica, California, May 1-3. Plan to join us for a major, in-person event focused on scaling impact. Sponsored by Digital Niche Agency, ProActive Real Estate and others. This will be a can't-miss event. Has your business been impacted by the recent fires? Apply now for a chance to receive one of 10 free tickets to SuperCrowdLA on May 2nd and 3rd and gain the tools to rebuild and grow!Community Event Calendar* Successful Funding with Karl Dakin, Tuesdays at 10:00 AM ET - Click on Events* RootsCamp, A powerful and unique (un)conference in Baltimore for progressive organizers to reflect on the election and share lessons and strategies to build our future, January 23-25th.* Community Capital Live, Bernel Hall, New Jersey Community Capital, January 29, 2:00 PM Eastern.* Igniting Community Capital to Build Outdoor Recreation Communities, Crowdfund Better, Thursdays, March 20 & 27, April 3 & 10, 2025, at 1:00 PM ET.* NC3 Changing the Paradigm: Mobilizing Community Investment Funds, March 7, 2025* Asheville Neighborhood Economics, April 1-2, 2-25.* Regulated Investment Crowdfunding Summit 2025, Crowdfunding Professional Association, Washington DC, October 21-22, 2025.If you would like to submit an event for us to share with the 8,000+ members of the SuperCrowd, click here.We use AI to help us write compelling recaps of each episode. Get full access to Superpowers for Good at www.superpowers4good.com/subscribe

Today Jim Garrity revisits the headaches caused by examining lawyers who frequently interrupt your deponents' answers. To combat this problem, Garrity offers you a six-pronged strategy for stopping this practice and/or creating a strong record that will allow your deponents to later add materially to their interrupted testimony, whether by errata sheet, affidavit, or live testimony. Courts are far more likely to allow that where you've used Garrity's strategies. (By the way, if you have a moment, would you send our production team a small "thank you" by leaving us a five-star rating wherever you listen to our podcast? It takes just 30 seconds - we timed it! - and it's deeply appreciated. Our crew devotes a great deal of time to research and production, and the podcast is not only free, but also uncluttered by pesky advertising. Thank you so much.)SHOW NOTESIn re Injectafer Prod. Liab. Litig. ALL CASES, No. CV 19-276, 2022 WL 4280491  (E.D. Pa. Sept. 15, 2022) (“Defendants propose. . . changing “It would be one of the—yes” to “It would be one of the sources of information. Yes.” This change is not necessarily inconsistent with the original testimony because it appears that the deponent was cut off or otherwise stopped speaking in the middle of the sentence and is justified as making the answer more complete. See id. While finishing a thought is not necessarily a proper justification for an errata modification, here it appears to be justified and within the flexible scope of the Third Circuit's approach to Rule 30(e)")Grey v.  Amex Assurance Company, 2002 WL 31242195, No. B152467 (Ct. App. Calif. Oct. 7, 2002) (reversing summary judgment in part because trial court abused discretion in failing to consider errata sheet containing “changes. . . made because the witness was interrupted before completing her answers;” further noting that the defendant “. . .took the risk that [the plaintiff's] corrections would bring some of its undisputed facts into controversy”)Arce v. Chicago Transit Authority, 311 F.R.D. 504, 512 (N.D. Ill. 2015) (denying, without prejudice, motion to strike errata sheet, as motion failed to specifically discuss many of the 67 changes defendant wanted stricken; noting that “The reason given for the vast majority of the 67 changes was that [Plaintiff] “did not finish” her answer during the deposition, though the transcript does not reflect that she was interrupted and prevented from doing so,” and outlining how various courts and commentators deal with the extent to which changes to testimony can be made on errata sheets)Arce v. Chicago Transit Authority, F.R.D. 504, 512, fn. 5 (N.D. Ill. 2015) (noting that, if one looks back at the early origins of the rule on errata sheets, quoted in this opinion, it may be argued that the intent of the drafters was indeed to limit changes to clerical-level mistakes, not to allow substantive changes): "One commentator who examined the history of the rule dating back to the original Equity Rule 67, and the twin Equity Rules 50 and 51 that succeeded it, concluded that Rule 30 was never intended to allow for more than the correction of transcription errors: "Appeals to the plain language of Rule 30(e) are incomplete and misleading without reference to the Rule's transcriptive focus. Read in historical context, the Rule appears to be distinctly clerical, ill-equipped—and never intended—to embrace substantive changes. Although its wording has changed over time, Rule 30(e) has retained one modest but steady focus: the who, how, and what of accurate transcription. The Rule is meant to secure an accurate representation of what was said, leaving to another day (and frequently to the mechanisms of Rule 56) the question of the meaning and implication of the deposition content for purposes of material factual disputes. The common understanding of Rule 30(e) has moved far afield from that mild ambition, giving us the confusion and circuit split we know today. Read in light of its history, the Rule clearly embraces a transcriptive focus. Ruehlmann, Jr., supra, at 915. Rule 30(e)'s counterpart in Illinois state court, Supreme Court Rule 207(a), was amended to limit corrections to transcription errors because the “potential for testimonial abuse” had “become increasingly evident as witnesses submit[ted] lengthy errata sheets in which their testimony [was] drastically altered....” Ill. Sup. Ct. R. 207(a), Rules Committee Comment to Paragraph (a) (1995)Arce v. Chicago Transit Authority, 311 F.R.D. 504, 511 (N.D. Ill. 2015) (citing Deposition Dilemmas: Vexatious Scheduling and Errata Sheets, 12 Geo. J. Legal Ethics 1, 60 (1998), for its author's argument that Rule 30(e) permits “opposing counsel, at her choosing, to introduce both versions to the jury”)Thorn v. Sundstrand Aerospace Corp., 207 F.3d 383 (7th Cir.2000) (observing, as to changes in errata sheet, that what the witness “tried to do, whether or not honestly, was to change his deposition from what he said to what he meant;” quoting the common refrain that “a deposition is not a take home examination,” the court remarked that while this was a “questionable basis for altering a deposition.” the court would allow the change under Rule 30(e) since the rule expressly “authorizes ‘changes in form or substance'.”Tchankpa v. Ascena Retail Group, Inc., No. 2:16-CV-895, 2018 WL 1472527 (S.D. Ohio Mar. 26, 2018) (refusing, based on Sixth Circuit's strict interpretation of errata sheet changes, to allow “. . .impermissible substantive alterations to Tchankpa's testimony. . .”, including explanations stating “Incomplete; I was cut off,” allegedly because “defense counsel interrupted him;” “In this circuit, a deponent cannot make substantive changes to his deposition testimony under Rule 30(e) based on defense counsel's interruptions. . .”)Hirsch v. Humana, Inc., No. CV-15-08254-PCT-SMM, 2017 WL 9991896, at *2 (D. Ariz. Nov. 17, 2017) When a party makes changes to his deposition pursuant to Rule 30(e), the original answers remain part of the record. See Thorn v. Sundstrand Aerospace Corp., 207 F.3d 383, 389 (7th Cir. 2000) (“[T]he rule requires that the original transcript be retained (it is implicit in the provision of that rule that any changes made by the deponent are to be appended to the transcript) so that the trier of fact can evaluate the honesty of the alteration.”); Arce v. Chicago Transit Authority, 311 F.R.D. 504, 511 (N.D. Ill. 2015) (“Subject to the rules of evidence, the jury is permitted to hear the original answer, the change, and the reasons for the change and decide – in the context of all the other evidence – whether to credit either answer and what weight to assign it.”); Coleman v. Southern Pacific Transportation Co., 997 F. Supp. 1197, 1205 (D. Ariz. 1998) (accepting the argument that “a change in a deposition statement does not eradicate the deponent's original answers”); Lugtig v. Thomas, 89 F.R.D. 639, 641-42 (N.D. Ill. 1981) (“Nothing in the language of Rule 30(e) requires or implies that the original answers are to be stricken when changes are made.”). The reason for this is obvious: “[t]he Rule is less likely to be abused if the deponent knows that ... the original answers[,] as well as the changes and the reasons will be subject to examination by the trier of fact")Hirsh v. Humana, Inc., No. CV-15-08254-PCT-SMM, 2017 WL 9991896, at *2 (D. Ariz. Nov. 17, 2017) (court-ordered second deposition of plaintiff did not extend deadline for submitting errata sheet following delivery of transcript from first deposition; counsel claimed he “believed that the first deposition did not ‘count,' because it was ordered [to] be redone, and therefore corrections were reserved”; errata sheet rejected as untimely)Neutrion Dev. Corp. v. Sonosite, Inc., 410 F. Supp. 2d 529, 550 (S.D. Tex. 2006) (allowing and considering – without apparent challenge or concern – expert's substantive changes to errata sheet, necessitated “. . . [because he] began to explain the knowledge that one of ordinary skill in the art would possess, but was interrupted by Neutrino's counsel”)Trout v. FirstEnergy Generation Corp., 339 F. App'x 560, 565 (6th Cir. 2009) (noting argument made by defendant that plaintiff “. . . is not entitled to benefit from her corrected deposition testimony because her counsel did not rehabilitate her statements during the deposition,” meaning plaintiff's counsel could and should have asked followup questions while the deposition was in progress)Bahrami v. Maxie Price Chevrolet-Oldsmobile, Inc., No. 1:11-CV-4483-SCJ-AJB, 2014 WL 11517837, at fn. 2 (N.D. Ga. Aug. 4, 2014) (Although Plaintiff's brief in response to Defendant's objections discusses a long day and interruptions by Defendant's counsel during the deposition, those reasons were not provided in the errata sheet. The Court also notes that if Defendant's counsel interrupted Plaintiff such that he could not elaborate much as he wished, Plaintiff's counsel had the opportunity afterwards to examine her client on those points and did not do so.”)Fed. R. Civ. P. 30(e)(1)(B) (federal rule of civil procedure on errata sheets, which expressly contemplates possible changes in form or substance)Fed. R. Civ. P. 30(c)(2) (requiring objections not just to evidentiary issues but to a party's conduct, to the manner of taking the deposition, and to any other aspect of the deposition)Fed. R. Civ. P. 32(d)(3)(B)(i) (requiring objections to errors or irregularities at an oral examination if they relate to the manner of taking the deposition, a party's conduct, or other matters that might have been corrected at that time)

Sounds of Crime

We're closing out this year's No Rules November by taking a trip back to one of our favorite countries, Spain. Eugenio Martin's A Candle for the Devil (not the censored It Happened at Nightmare Inn version) packs a punch and is a worthy entry for the 100th film that we have covered.Watch it here: https://www.youtube.com/watch?v=PdPoqpC0tPA&list=WL&index=10Join our discord! https://discord.gg/F8WsTzE9qtFollow this podcast on Instagram and Facebook @unsunghorrors.Follow Lance on Instagram and Letterboxd @lschibiLance's shop: https://lanceschibi.bigcartel.com/Follow Erica on Letterboxd or Instagram @hexmassacreLogo by Cody SchibiPart of Someone's Favorite Productions Podcast Network:  https://linktr.ee/someonesfavoriteproductions

Sounds of Crime

The first ever Aztec death whistle was found in Mexico City in the late 90s in the grave of a 20-year-old male who was the victim of a sacrifice. Beheaded, & with his arms crossed over his chest, the death whistle was found clutched within his skeletal hand. One of the most remarkable ancient musical instruments ever discovered, the sound of the Aztec death whistle has perplexed scholars for years. According to recent studies, it is so un-nerving that it can literally mess up your mind. In this episode, I actually play the sound of this infamous resonator for several seconds, but be warned that it might be one of the creepiest sounds you've ever heard. Why did the Atec's create these strange resonators? What were the actual results from the scientific tests? Watch to find out 2025 PERU &/or EASTER ISLAND TOUR Sources: https://youtu.be/byG5TM0j0D8?si=Gy2fcks6C8kw76Ge https://www.ancient-origins.net/artifacts-other-artifacts-news-history-archaeology-ancient-places-americas/aztec-whistle-0021706 https://youtu.be/Y5szkAecabU?si=oLftvKS6oTXcKV_Z  https://www.youtube.com/watch?v=Z-YfHg2_vjI&list=WL&index=7  

Have you ever been in a deposition and noticed something improper and prejudicial, but couldn't think of a precise objection to make? There might not be one. For example, many deponents now appear by remote video in unconventional settings - living rooms, hotel lobbies, or their cars - where others are present and may disrupt or influence the testimony. The rules' drafters couldn't possibly anticipate these new challenges. So, for misconduct that isn't squarely covered by a specific objection, Jim provides you with a single broad "super-objection" that will cover virtually any irregularities. This will help protect your right to exclude testimony, or the entire deposition, as needed. (As always, thank you for listening, and please take 30 seconds and leave us a 5-star review wherever you get your podcasts. It's a fast, free, and fantastic way to thank our production crew. We deeply appreciate it.)SHOW NOTESRatliffe v. BRP U.S., INC., et al., No. 1:20-CV-00234-JAW, 2024 WL 4728898 (D. Me. Nov. 8, 2024) (order denying motion in limine to exclude deposition where witness' mother assisted deponent while testifying; held, objections to alleged impropriety waived)Fed. R. Civ. P. 30(d)(3)(A) (allows court relief where deposition is being conducted in bad faith or in a manner that unreasonably annoys, embarrasses, or oppresses the deponent or party)Fed. R. Civ. P. 32(d)(3)(B) (deeming objections waived if not made during the deposition where objection is to any irregularity in the way the deposition is being conducted)Fed. R. Civ. P. 26(c) (allowing protective order permitting or forbidding discovery if necessary to ensure fair proceedings)Fed. R. Evid. 403 (allowing exclusion of evidence on grounds of unfair prejudice, confusing the issues, misleading the jury, undue delay, wasting time, or needlessly presenting cumulative evidence)United States v. Simmons, 515 F. Supp. 3d 1359, 1364 (M.D. Ga. 2021) (“While “unreasonable” and “oppressive” are not defined under Rule 17, they have a common sense meaning, and courts finding a valid and specific privilege may quash subpoenas on that ground”)Heartland Hotel Corp. v. Nat'l Union Fire Ins. Co. of Pittsburgh, PA, No. CV 07-2147, 2008 WL 11440623, at *8 (W.D. Ark. Aug. 5, 2008) (“Oppressive ” is defined in Webster's Third New International Dictionary as “unreasonably burdensome” and “unjustly severe, rigorous or harsh”)

Divine baby Gabi Kovalenko (codes 15-30min): https://youtu.be/v75fukxtzcs?si=1vcoZxbGfyw8TIx9 The Deepest Twin Flame Video Ever Made: https://www.youtube.com/watch?v=o8Av2iYrXQ4&list=WL&index=2&t=13s ➖➖➖➖➖➖➖➖➖➖➖➖➖ Ich küsse deine Narben https://morenutrition.de/ code: FERDI YouTube English: https://www.youtube.com/Vegains YouTube DE: https://www.youtube.com/VegainsDE German Rap: https://www.youtube.com/@Vegainsrap Instagram: https://www.instagram.com/vegainstrength Instagram DE: https://www.instagram.com/vegains/ My DE Amazon: https://amazon.de/shop/vegainsde Listen to my podcast: https://anchor.fm/ferdibeck German podcast: https://anchor.fm/ferdibeckde Website: https://www.vegansavage.com

Today Jim Garrity tackles the topic of narrative objections, which are objections that go beyond a simple "Form!" or "Objection!" and provide a concise explanation of the grounds for the objection. Some litigators see anything beyond a single word as a speaking objection or as coaching, but that's not so. Jim untangles the spaghetti in this episode.(By the way, there are two cases and rules listed in the show notes. If you don't see them all, click through to our podcast page, and you'll find them there. Some hosting sites truncate show notes to save space. And, if you have a moment, would you please leave us a 5-star rating wherever you're listening to us? It takes less than 30 seconds, but it's a huge incentive for us to put these episodes together. We offer critical expert insights in this podcast, as well as the research to back it up, and it's all free. The 5-star ratings are a great way to send us a thank you back. Thanks!)SHOW NOTESB.P. v. City of Johnson City, No. 2:23-CV-71-TRM-JEM, 2024 WL 3461408 (E.D. Tenn. July 18, 2024) (statement that pages were out of order or missing, following objection, wasn't improper “speaking objection” but, rather, articulated basis for objection; court also found no basis to limit defending lawyers to word “objection” during deposition, as lawyer must state basis for it)Dino Antolini, Plaintiff, v. Amy McCloskey, et al., Defendants., No. 1:19-CV-09038-GBD-SDA, Not Reported in Fed. Supp., 2021 WL 5411176, (S.D.N.Y. Nov. 19, 2021) (citing cases for proposition that objections should be made using the single word “Objection” unless the basis for the objection is requested; providing numerous examples of alleged speaking objections)R.D. v. Shohola, Inc., No. 3:16-cv-01056, Not Reported in Fed. Supp., 2019 WL 6134731 (M.D. Pa. Nov. 19, 2019) (in context of pretrial rulings, court declined to grant motion in limine barring speaking objections, saying, “However, because “we deem the question of what constitutes an improper speaking objection, an inappropriate comment on excluded evidence, or an improper ad hominem exchange to be fact bound matters which cannot be determined wholly in the abstract, we will defer further rulings on these motions pending proper objections at trial”)Fed. R. Civ. P. 30(c)(2) requiring objections to “be stated concisely in a non-argumentative and non-suggestive manner”)Committee Notes to 1993 Amendments (stating that new paragraph (1) at the time provides that “that any objections during a deposition must be made concisely and in a non-argumentative and non-suggestive manner;” rule does not tell us how to make an objection, such as by word “objection”)Brent v. Cramer, et al., No. CV JKB-22-1349, 2024 WL 3878145 (D. Md. Aug. 20, 2024), fn. 4 (providing examples of alleged speaking objections)Christie v. Royal Caribbean Cruises, Ltd, No. 20-22349, 2021 WL 2940251 (S.D. Fla. July 13, 2021) (examples of speaking objections)State Farm Mutual Automobile Insurance Company v. Dowdy, 445 F. Supp.2d 1289 (N. D. Oklahoma July 21, 2006)In re Stratosphere Corporation Securities Litigation, 182 F. R. D. 614 (D. Nevada 1998) (“This Court can find no better or more succinct definition or description of what is and is not a valid deposition objection than that found in Rule 30(d)(1): “Any objection to evidence during the deposition shall be stated concisely and in a non-argumentative and non-suggestive manner”)Mitnor v. Club Condominiums, et al., 339 F.R.D. 312, 317-318 (N.D. Fla. 2021) (describing some of the essential characteristics of an improper speaking objection)Fed. R. Evid. 103 (providing that in order to preserve and objection, a party must timely object or move to strike and state the specific ground for the objection, and less it is apparent by context)Fed. R. Civ. P. 32(d) (Waiver of Objections)