Page 18 - FDCC Deposition Drills

A FEW QUESTIONS TO DISCUSS
Why is learning as much as you can about your case important for taking effective depositions?
What information do you need in every case?
What information do you need for specific types of cases? What are formal ways to secure information?
What are informal ways to secure information?
How can you conduct your investigation privately, out of the eye of opposing counsel?
Deposition Drills How to Teach Deposition Skills
Information Gathering
As with documents, it is important to secure all relevant information before a deposition. The more you know about a witness, what she knows, her role in a case, and what she is likely to say, the more effective the deposition.
EXPLANATION
This exercise teaches how to define what relevant information must be secured for a deposition and how to secure it..
EXERCISE
Choose two or three types of cases your firm or practice group handles. Ask the participants to state all the relevant information that may be available in those cases and how best to secure them. As the exercise leader, have a list of the categories and types of information you rely upon and how you secure them and at the end of the exercise compare the participants’ lists to yours.
LESSONS LEARNED
Participants will learn the importance of conducting a thorough case investigation before taking the first deposition. Thorough due diligence improves the effectiveness of a deposition.
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SECTION 01 PREPARATIONS