Points to Cover About Deposition "Mechanics"
Explain protections for the witness that are built into the deposition rules. Describe the role of the defending lawyer, particularly with respect to objections and instructions not to answer. Set o..
Help the witness understand the usual preliminary questions asked at the outset of a deposition when the deposing lawyer tries to get the witness committed to give full and complete answers to the questions about to be asked. Explain the limits of th..
How to structure a productive role-playing session in which the adverse questioning likely to occur at the deposition is put to the witness in a practice exercise
Techniques for mock questioning to prepare the witness. Ways in which role-playin..
Teaching the witness how to respond to direct examination by the opposing lawyer with the shortest fair and truthful answer.
How to de-brief the witness on avoiding volunteering and rambling answers and help the witness answer more effectively w..
Explaining Helpful Techniques to a First-Time Expert
How the expert's role at a deposition differs from the role at trial; recognizing the opposition lawyer's goals; the mechanics of a deposition; likely questioning; and and useful techniques fo..
Helping the Experienced Expert Fit into the Case
Preparation on case themes, scope of retention, materials reviewed and qualifications. Thorough review of prior experience and opinions; how to fix errors in the expert's report; preparation for ..
Checklists for getting ready to defend a witness who Is testifying on behalf of an organization:
Choosing the right witness or witnesses to speak for and bind the organization; making objections or motions for protective order as to the scope..