Questioning a Witness, Funnel Technique
The funnel technique is all about efficiency. This video illustrates the use of the funnel technique for a situation where the witness overheard an important telephone conversation.: Deposition Skills, Taking
Especially in time-limited depositions, efficiency is important while not missing details that either could be helpful in piecing together the best explanation of the client's case or need to be countered in one way or another in defending the client's cause. The questioner extracts a list of each relevant thing that the fact witness saw, heard, felt, or otherwise became aware of. Then, with respect to each of the important items on the list, the examiner starts at the top of the funnel with the broadest, least directive questions. The examiner then moves toward the middle of the funnel with narrower and more specific who-what-where-when-why-how questions. Toward the bottom of the funnel, the examiner winds up with the most specific and directive questions to exhaust what the witness has to contribute. And at the end of the funnel the examiner sums up with leading questions capsulizing helpful points.
Ed Stein practices in Ann Arbor, Michigan. He has regularly taught trial and deposition skills for the National Institute for Trial Advocacy, Michigan... - complete bio
Deanne Siemer is a trial lawyer from Washington, D.C. who has tried technology-driven commercial cases before juries in state and federal courts aroun... - complete bio
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