Page 12 - FDCC Deposition Drills

Deposition Drills How to Teach Deposition Skills
The Power of Smartphones
Your most powerful deposition tool is in your hand – your smartphone. Use it to record young lawyers as you teach them deposition skills and then watch the videos with them. Point out their style, their cadence, their body language, their fillers, etc. and help them improve their voice, their delivery, their presence and their confidence. I didn’t have smartphones when I was a young lawyer and I would have learned so much by recording myself with one and studying my presence and behavior to improve my delivery.
What Deposition Skills Result in Effective Depositions
Effective depositions can be reduced to mastering certain skills, including conducting thorough due diligence before a deposition, thinking through and relying upon your case theme during the deposition, securing all relevant information the witness has to offer and directing the witness to provide you the information you want in the manner you want it. Some have the misconception that a deposition is purely a fact gathering expedition. That is one of the purposes of a deposition, but generally only a minor one. More often, you’re trying to get a witness to make admissions that make your case and undermines your opponent’s. You’re securing what you need to win at summary judgment, mediation or trial. Teaching deposition skills that win cases is what you’re aiming for.
6
©2021 Federation of Defense & Corporate Counsel