Page 22 - FDCC Deposition Drills

A FEW QUESTIONS TO DISCUSS
Why is it important to arrange your topics a certain way?
Why is it important to arrange your questions under each topic a certain way?
What is the typical order of topics in depositions?
How can you change the typical order? What affect does that have on the deponent? On opposing counsel?
When should you ask the “money” questions that secure favorable admissions? How do you lay the foundation for those questions?
How do you use the flow in your favor? How can you use the flow to trick, trap or corner a deponent?
Deposition Drills How to Teach Deposition Skills
Flow of Questions
Every deposition has its flow, in terms of how each topic transitions into the next and how each question transitions into the next. Learning how to order topics and questions will help you secure the answers you’re seeking.
EXPLANATION
Participants learn how to organize deposition topics and questions and how to segue from one to the next.
EXERCISE
Choose a common type of deponent from your matters. Brainstorm the topics to ask and discuss what order to arrange those topics and why. Cull out several topics and discuss what questions to ask under those topics, what order to ask those questions, why those questions should be asked and why they should be asked in a given order.
LESSONS LEARNED
Participants learn the importance of not just asking the right questions, but asking them in the right order.
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SECTION 01 PREPARATIONS