Leave Room for Annotations by Resizing PDF Documents

Contrary to the Exxxtenz advertising campaign, sometimes smaller is actually better. Take that PDF roll of client documents you just scanned or all those deposition transcripts. Wouldn't it be nice to have enough room in the margins to make fail-safe, "don't skip this, stupid" annotations (either by hand or with PDF-Xchange Viewer)?

Thanks to modern technology, you can get smaller immediately, and without the aid of high-priced pills or Swedish-made suction devices. If you have an existing PDF file, just reprint it using CutePDF, but scale down your print size to about 75-80%. That will leave plenty of room in the margins for you to make your big, bold notes (and hopefully reduce the need to do document or deposition summaries).

The little blurbs you can make with Adobe or PDF-Exchange Viewer are nice. Actually making the notes within the printable space on the document, however, means no one will miss the boat as a result of being unfamiliar with your .pdf software.

Making Non-Party Discovery Work

Here's a short list of tips for ensuring that you don't have to make a routine practice of seeking to hold non-parties in contempt for not responding to discovery requests.

1. Call the non-party beforehand and explain what you are about to do.

Even a monkey could figure out why this is important.

2. Use a law enforcement official to serve the subpoena on normal folks.

In Texas, anyone over 18 that is not a party can serve a subpoena in a civil case. If you're serving an engineer or a doctor, chances are they know what it is and that they're suppose to take it seriously. If you're serving an 22-year-old overnight stocker at a grocery store, they've probably never seen a subpoena before and may very well throw it in the trash if some 18-year-old runner hands it to them. The authority of the "badge" works wonders.

3. Write the document request or deposition notice in a way that tells a normal person what to do.

If you want to the recipient to do the job right, tell him or her step-by-step what to do and explain the process in a way that's conducive to someone who's probably worried about getting sued. Whatever you do, don't just cut-and-paste a form book non-party discovery request--I've seen better command of the English language on a restroom door. I've found using headings like a FAQ webpage works well:

I. Have I been Sued?
II. What Right do You have to Request Information from Me?
III. Will I be Paid for My Time and Effort?
IV. When Do I Need to Respond?
V. How Do I Need to Respond?

You get the idea.

4. Call the non-party after the subpoena is served and arrange for document pick-up or deposition logistics.

Establishing a level of comfort or respect with the witness is crucial for avoiding a courthouse contempt hearing. So is making sure the witness knows where to go, what to bring, and when he or she will be able to pick up the reimbursement check.