I. Introduction

Attorneys experienced in defending depositions know the importance of witness preparation. A key component of this process requires counsel to sift through large amounts of produced discovery to identify specific documents ripe for examination by opposing counsel. An interesting issue unfolds when an examining attorney asks a witness during the deposition to recount

I. INTRODUCTION

Premises owners of commercial establishments have relied on Chapter 95 of the Texas Civil Practice and Remedies Code (“Chapter 95”) to defend against negligence actions brought by independent contractors since its advent in 1996. Chapter 95 affords premises owners complete immunity against claims (1) based on the personal injury, death, or property damage