Deposition practice handbook: how to take and defend depositions
This practical handbook explains when, why and how to use particular strategies, tactics, organizational approaches, methods, and techniques in taking and defending depositions. Packed with 'trade secrets' that one-up the opposition, Deposition Practice Handbook shows you: How to pin down and 'freeze' witnesses' testimony with an early deposition so they can't change their story later How to make a deposition a lot more effective by getting an interrogatory answered first Twelve proven ways to discredit a witness How not to open Pandora's box when questioning a third-party witness How to avoid the trap of allowing your opponent to set the deposition times And, most important of all: How to turn talk into evidence that's admissible in court What's more, Martiniak provides checklists, outlines, reminders, and dozens of practice tips.
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Chapter 1 A General Perspective on Depositions
Chapter 2 Preparing for a Deposition
Chapter 3 Getting Started at the Deposition
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accident admissions adverse party adverse witness ALVIN SMITH answer areas ask the witness client Compco computers conduct Confidential copy court reporter cross-examination defendant deponent deposing attorney deposition testimony designated disclosure discovery discussed document request elicit employee evidence examination EXAMPLE EXCESS REFINANCE FUNDS Exhibit 99 expert explore facts Federal Rules give grommets hearsay impeach important inspection interrogatories issues Jones jury leading questions motion ness notes notice November 17 November 28 objection opponent opposing counsel otherwise outline party witness person plaintiff preparation prior privileged production protective order reasonable recollection record refer regarding this subject relevant require response ring binder scheduling statement stipulation subject matter subpoena subpoena duces tecum sure taking the deposition talk tell the witness testify third-party witness tion told transcript trial unless vehicle videotape waived wish witness knows witness's testimony witnesses regarding