933 Studewood St., 2nd Floor, Houston, TX 77008
Tel: (713) 426-5600 Toll-free: (866) 654-5600

Articles and Papers

Following are downloadable research papers or presentations given by Paul N. Gold.

Dancing with Wolves in Drag (Adapted for Louisiana Practice) —07/27/11 (523 KB)

Dancing with Wolves in Drag—Tactics and Strategy with Regard to Defense Requested Mental and Pysical Exams (DME's)—07/08/11
(3.4 MB pdf)

I'd Rather Be Fishing - Scope of Discovery in Texas 2011
(252 KB)

Is It Bigger Than a Breadbox? Is It Smaller Than a Barn? Discovery of Damages in Texas 2011
(229Kb)

Deposing the Ventriloquist’s Dummy (Presentation)—10/07/10
(160Kb)

Thoughts on Deposition Practice in Texas 2010
(164 Kb)

Substantive & Tactical Considerations in Taking Depositions
(1.16 MB)

Discovery Update 2010 (06-04-10)
(224 Kb)

"I'd Rather Be Fishing" 2010 Supplemental Update
(128Kb)

“Questioning God” Issues and Tactics When a Party is Designated as a Testifying Expert
(161 Kb)

“I’m Melting” Protecting the Plaintiff and the Jury from the Adverse Medical Examiner
This paper has been replaced by Dancing with Wolves in Drag—Tactics and Strategy with Regard to Defense Requested Mental and Pysical Exams (DME's)—07/08/11
(3.4 MB pdf)

2009 Discovery Stimulus Package: Texas Discovery Update
(107.6Kb)

Jack be Nimble; Jack be Quick: A Trial Lawyer's Thoughts on Discovery Motion Practice in Texas
(K)

Discovery Update 2008: We Still Get Peanuts; The Bags Are Just Smaller
(96.4Kb)

You-Tubephoria: Musings On The Tactical And Creative Use Of Videotape Deposition Demonstrations
(62.4Kb)

Discovery Of Objections And Requests For Protection: The Back Game (1996)
(3.60Mb)

“Paper Mache”: Thoughts on Drafting Discovery (1998)
(250.5Kb)

Talking Heads, Speaking Objections And The Usual Agreements: Procedural And Practical Tips For Effectively Taking And Using Depositions (1999)
(227.8Kb)

Talking Heads, Potted Plants And Speaking Objections: Understanding The New Rules Of Deposition Practice In Texas (1999)
(91.8Kb)

Discovery Of Experts: So You Want Something From The Great Oz?! (2003)
(2.83Mb)

“Running and Gunning for Justice”: Strategies for Formulating and Implementing Scheduling Orders in Medical Malpractice Cases (2005)
(65.5Kb)

“So, Who Died and Made You King?”: Discovery of Experts (2006)
(60.2Kb)

“Kinesiolawgy”: A Study of Pre-Trial Motion Practice in Texas (2007)
(185.7Kb)

“I'd Rather Be Fishing”: Scope of Discovery in Texas (2007)
(161.5Kb)

"Deposing the Ventriloquist's Dummy": A Discussion Of When And How To Take Depositions Of Organization Representatives
(1.97Mb)

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Paul marking up document with red marker

 

 

Paul drawing a brain

drawing of Paul Gold at a podium

Drawing of Paul Gold speaking
by a young Alex Gold

 

Aversano & Gold

933 Studewood St.
2nd Floor
Houston, TX 77008
Tel: (713) 426-5600
Fax: (713) 426-5601
Toll-free: (866) 654-5600

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