The pleadings are closed. The documents are exchanged. The evidence has been assessed. The trap is laid. The case is framed. Ready to prove but for a sweet set of tasty admissions. All you need is to take the right depositions, engage with the knowledgeable people, and align their sworn views into your theory of the case. Once in line, if necessary, you proceed to trial to make them confirm your victory on cross!

Sounds like a plan until the phone call, the complication, and the COVID-19 crisis disrupts your ability to take the precious testimony. Opposing counsel, the court, the parties—they all say things must be delayed; and when resumed, they can occur in only a dreaded videoconference. Not Zoom. Not Microsoft Teams. It will disrupt the questioning, break the cadence, dispel any chance of a human conversation in which admissions may flow. It will ruin everything—or will it?

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