Time: 13:10 Dealing with the Reporter and Transcript:
Information for the court reporter, making an alternate record, arrangements for the transcript, attaching documents, going on and off the record, swearing the witness...
Time: 8:41 Asking the Preliminary Questions:
"Commitment" questions establish a basis for challenging any later modifications by the witness; "no excuses" questions establish that the witness is not under any temporary disability..
Time: 13:02 Basic line of questions to find out if useful information relevant to the case might be on the witness's social media:
Techniques to use deposition discovery with respect to the content of social media posted by a lay witness..
Time: 11:23Basic line of questions to find out if useful information might be on the witness's social media:
Techniques to use with respect to the content of social media, professional sources, blogs, recovering deleted info..
Time: 17:39Exploring a Claim of Attorney-Client Privilege:
Testing whether the claim of attorney-client privilege meets all the requirements to support an instruction not to answer questions about the substance of a communication with a lawyer...
Time: 5:40 How to Question a Witness Who Frequently Says "Can't Remember" or "Would Have to Guess":
Witness coaching by opposing counsel before the deposition may result in useless initial answers. How to get around this..
Time: 18:05 Factors to Consider in Laying an Adequate Foundation and Defending Against Objections:
Why laying a foundation at a deposition is different from the drill
at trial; how to be sure you've included all the necessary elements..
Time: 16:25 Special Considerations in Laying a Foundation for E-Mail Chains:
How to deal with e-mail chains in laying a foundation with a witness who is only one of the parties who created the chain; methods for authentication; meeting hearsay o..