Page 27 - FDCC Deposition Drills

Deposition Drills How to Teach Deposition Skills
Using Photos
Often, you’ll need to show a witness a photo and have her identify it and describe it. The photo needs to be properly identified for the record, and the photo and what it depicts properly described for the record. Some photos are simple. Some have more content and are more complex. Becoming comfortable with using photos in depositions is an important skill to develop.
EXPLANATION
Participants learn how to use photos with a deponent.
EXERCISE
Take several photos you have used in past depositions or simply print stock photos you find online. Have the participant identify and mark the photo for the record and ask you questions about the photo. The participant must accurately describe the photo and its contents for the record and clear up any confusion about the photo’s content and secure whatever information or understanding you have about the photo.
LESSONS LEARNED
It’s said a picture is worth a thousand words. Often, photos of an accident scene, a vehicle, a product, or a condition play important roles in cases, depositions and trials. Knowing how to use photos to support your case is a skill that takes practice.
A FEW QUESTIONS TO DISCUSS
Why are photos important for a case?
How can you use a photo effectively in deposition?
What if a photo hurts your case? How should you use it? How can you use photos to support your theme?
How can you use photos to tell your story?
©2021 Federation of Defense & Corporate Counsel
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SECTION 03 USING EXHIBITS