Page 20 - FDCC Deposition Drills

A FEW QUESTIONS TO DISCUSS
What are common deposition goals?
What are deposition goals which are not obvious or readily apparent? How do goals direct your questioning in deposition?
How do you determine the order of importance of your goals?
How do goals change during the course of a case?
What is the relationship between your case goals and your case theme? How do goals focus your questioning?
Deposition Drills How to Teach Deposition Skills
Developing Goals
As with everything we do in a case, one needs goals when taking a deposition. What information are you trying to procure? What admissions are you trying to secure? What themes do you want to develop? Depositions are more than asking questions and soliciting answers. They are about advancing your overall case goals toward achieving a win. Learning to develop goals for depositions ensures that the questions one asks best serve the case and the client.
EXPLANATION
This exercise teaches how to brainstorm and develop deposition goals.
EXERCISE
Choose two or three types of cases your firm or practice group handles. Ask the participants to brainstorm deposition goals for those cases. Lead a discussion about possible deposition goals and how to achieve them in depositions. Have the participants write out their deposition goals, organize them in importance and discuss how those goals will drive what to ask at deposition.
LESSONS LEARNED
Participants learn how to define deposition objectives, which drive what to ask the deponent and how to ask her those questions.
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SECTION 01 PREPARATIONS