Deposition Questioning Strategies and Techniques
Provides descriptions and illustrations of effective strategies and techniques for taking and defending depositions. Designed to serve as a text for a 2-4 unit stand-alone depositions course or as a supplement to a civil pre-trial lawyering course. Devotes separate chapters to such fundamental skills as obtaining helpful answers to critical questions, undercutting harmful testimony, obtaining a deponent's version of significant events, and obtaining information from evasive deponents. Other chapters include topics such as responding to inconsistent or implausible testimony, overcoming opposing counsel's objections and obstructionist tactics, and preparing a client to be deposed.
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PART ONE DEPOSING ADVERSE WITNESSES
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accident admission admonitions adversary adversary's adverse witness argument ask a deponent ask the deponent assume behavior breach of warranty Chapter chronology Civil 2d client conclusion correct court reporter credibility customers decide deed of trust defendant Delaney told depo deponent testifies deponent's testimony deponent's version deposing deposition testimony deposition transcript discussion documents elicit employee Exhibit 27 expert explanation FRCP Freeman Gillig Guzek happened harmful answer harmful evidence harmful testimony helpful evidence identify impeachment implausibility improper inconsistency indicating inference inquiry instruction Korobkin lawyer lease Lester loan meeting objection obtain occurred opinion opposing counsel Park Park's report person plaintiff plausibility chain potential pre-deposition prepare prior probe problems protective order ques reasons recall record Red Rooster remember respond risks seek Spillenger statement stipulation strategies supervisor T-Funnel talk techniques tell me everything Timeline tion topics trial typically undermining harmful videotape wrongful termination