This is a practical guide for the trial attorney. The set provides the fundamental legal research about depositions, their scope, and procedure specific to Texas cases. It also provides checklists for taking the depositions in various types of lawsuits. Just as an experienced pilot would never take off without reviewing a checklist, even the most experienced attorney can and should use these checklists when taking depositions to ensure nothing gets missed. These volumes are classic in their field, and are considered by many trial lawyers to be the best "real life" guides to depositions. Key features include: • Ironclad strategies, proven forms • Checklists tailored for any type of witness • Up-to-the-minute case law • Federal and state rules and statutes • Foreign depositions • Important tips for addressing e-discovery ... and much more!