Waiting until 30 or 45 days before the pretrial conference for a party to give notice of the experts it intends to call is ridiculous. Suddenly, too close to trial, you have to depose people. File a motion on disclosure of experts early and get the experts deposed early. Do not let your opponents do any examination or testing of products, materials or premises without making sure the test is recorded on video. File a motion and argue your position.
Testing preserved on video is preserved forever.
Generally, get testing done on video as often as possible. When you want telephone or videotape depositions, consider filing a motion that will set forth in detail the administrative and organizational procedure. This will save you a great deal of time when it comes to using the depositions later. JURY VIEW Think carefully about this motion early. If appropriate, file it early and get a hearing on the matter early.