pretrial — "The Velvet Hammer" Blog

How to take an excellent one hour expert deposition.

My biggest pet peeve is waste of time legal events. Depositions are at the top of the list. Am forever tearing my hair out when a defense lawyer says to a seasoned expert:

Q I’m assuming you’ve had your deposition taken before.

A Hundreds of times.

Q And you probably know the rules.

A I do.

Q Well, let me go over them with you just for the record.

Gaaah. Why. What is wrong with us as a profession. Why are we wound so tight. So self important. So scared of making a mistake. That we think we need to make a record of everything no matter how mundane.

pretrialKaren KoehlerFebruary 28, 2026deposition, experts

The incredible beauty of a blue sky insurance letter

he first time I experienced a “blue sky” letter was in 2003. My friend Bill Bailey, a PI lawyer who I taught law school with, needed a miracle. His client, a young girl, had been the back seat passenger in a car that was speared by another. The girl sustained massive head and facial injuries from the direct hit. The driver had low policy limits.

Bill sent me the case because he was at his wits end and wanted me to “think outside of the box.” I decided to sue the school for allowing the girl to be driven by a friend’s mother without written permission. It was a slim case. But sometimes cases get better.

pretrial, trialKaren KoehlerJanuary 19, 2026insurance, bad faith, personal injury

Trial prep: anticipating the enemy

We are going to trial again. Against my nemesis. R.L.

The last time was a five week trial in the fall of 2022. We thumped him hard. He deserved it. I’ll never forget watching the sneer get wiped right off his face as the judge read the jury verdict. Three and a half years later his clients are still trying to appeal it.

And so we face off again. Nothing has changed

pretrial, trial, humanKaren KoehlerJanuary 3, 2026grandma, defense lawyers

Seattle employs age old propaganda tactic against Gas Works Park victims

The City fired its opening salvo in the Gas Works Park nuisance lawsuit filed after the death of 15 y.o. Matthies Johnson. This is how the City’s Answer begins:

“The City admits that some trespassers at Gas Works Park who have climbed or attempted to climb the appurtenances to the fenced-in towers have been injured and died in falls.”

The City does not refer to Matthies Johnson or the other 14 young people as humans with names and ages, families and friends. It classifies them as negative disembodied entities. Law breakers. Bad people. Trespassers.

human, pretrialKaren KoehlerNovember 20, 2025city of seattle, gas works park, government legal defense

The Velvet Hammer Podcast Version 2.0 with Mo Hamoudi

The Velvet Hammer Podcast (TM) was becoming not exactly a chore. And not exactly a bore. But it was destined to either dry up and wither away slowly. Or it needed a major redo.

human, pretrial, trialKaren KoehlerFebruary 4, 2025podcast

Dear (upset) defense lawyers: No one is forcing you to read my blog.

pretrialKaren KoehlerJune 4, 2023defense lawyers, free speech

How much a government will spend to fight the little guys

Have you ever wondered how much a city will spend in legal fees - to defeat a lawsuit. Let’s say for example, one brought by peaceful BLM protesters who claim their First Amendment rights were violated when the city’s police pepper sprayed, tear gassed, flash banged, blast balled and body slammed them.

pretrialKaren KoehlerMay 9, 2023civil rights, defense lawyers, government legal defense

Apology nope - not then not now. The ongoing saga of the SPD's unrepentant violent response against peaceful BLM protesters

Forgive me for laughing hysterically at the concept of the City of Seattle owning up to its brutalization of peaceful protesters. As was just recommended by the 4th Sentinel Review - the City supported investigation and look back at the SPD’s response to the George Floyd protest season.

pretrialKaren KoehlerApril 19, 2023blm, civil rights, motion

What it's like to represent 50 BLM peaceful protesters against the City of Seattle

Today am covering the deposition of JR - a protester whose hand was struck by a blast ball munition thrown by the SPD. As he was trying to leave the protest zone. While this deposition is going, Shannon and Kristin are doing final edits to the massive summary judgment oppositions that are due today - motions brought by the City to dismiss two other protesters’ claims.

pretrialKaren KoehlerApril 3, 2023blm, civil rights

On not talking to adjusters

Once was asked to give a speech on how to communicate with adjusters. Showed up and told the group that my rule of thumb was to never talk to them at all.

pretrialKaren KoehlerAugust 25, 2022insurance

Mediation No

In furtherance of our study of mediation technique and the prettiness of our craft, see below.

From: Mediator
Sent: Thursday, July 28, 2022 2:09 PM
To: Karen Koehler <karenk@stritmatter.com>
Subject: Re: Mediation of A v. B 6/1/2022, 9:00 a.m. – 1:00 p.m.

Hi Karen,

I spoke with R.L. on another matter and he advised that Allstate has re-evaluated after the mediation and is ready to re-engage in negotiations.

pretrialKaren KoehlerJuly 28, 2022mediation

Hammer Time: Responding to an obnoxious defense lawyer letter

It’s Friday afternoon. Hmmmm. What sounds like something fun to do. Why - how about respond to an obnoxious defense lawyer letter. Notice the operative word here. Not what do I have to do. Or what am I angry about. But what’s an upbeat way to end the week.

There is something super satisfying about fencing with a ponderously grumpy opponent.

pretrialKaren KoehlerMay 13, 2022obnoxious defense

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