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Exemplar Deposition Questioning

Samuel G. Livingston, P.C. places great emphasis upon conducting depositions during the course of discovery in most bad faith and personal injury actions. Mr. Livingston has provided multiple lectures to professional organizations surrounding bad faith and particularly deposition style and substance throughout the course of his career. Mr. Livingston is known in the insurance industry for his aggressive and thorough style of deposition questioning, and most significant, depositions in a case are both recorded stenographically as well as by videotape. Moreover, cases are typically presented at the settlement portion of the litigation by way of preparing a summary of multiple depositions.

This summary of deposition transcripts was further edited and presented as part of Plaintiff's opening statement in the matter of Peressini which resulted in a $3 million jury verdict. Portions of this transcript were also utilized by "when pigs fly"  relative to its media coverage surrounding "when pigs fly" which exposed American Family's business practices centering upon a Colorado State Business Plan which attempted to reduce claims payouts by approximately one-third over a four-year period based upon arbitrary considerations unrelated to the needs of the insureds under the contracts of insurance. This demonstrates a presentation which was actually shown to the jury at the beginning of the Peressini jury trial and was highly influential in establishing in the jury's minds the type of conduct which American Family engaged in even before the presentation of evidence began during the Plaintiff's Case-In-Chief.

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The Law Office of Samuel G. Livingston, P.C.
25188 Genesee Trail Road,
Suite 140,

Golden, CO 80401

Phone: 720-443-5876
Fax: 720-904-0471
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