Page 28 - FDCC Deposition Drills

A FEW QUESTIONS TO DISCUSS
How are diagrams different from photos?
How can you use diagrams effectively?
What are the most important aspects of a diagram? How can you use a diagram to support your theme? How can you use a diagram to tell your story?
Deposition Drills How to Teach Deposition Skills
Using Diagrams
Sometimes you’ll use a diagram in a deposition – a diagram of an accident scene affixed to a police report, a diagram of a floor plan, a diagram of a product – to question a witness. As with photos, you need to know how to identify the diagram and its contents and how to use it with a witness.
EXPLANATION
Participants learn how to use a diagram with a witness.
EXERCISE
Secure diagrams you have referenced in depositions or print several you find online. Have the participant identify and mark the diagram for the record and ask you questions about the diagram. The participant must accurately describe the diagram and its contents for the record and clear up any confusion about the diagram’s content and secure whatever information or understanding you have about the diagram. Diagrams are often done
to scale, so make sure participants ask questions about the scale, what is included and excluded in the diagram and any other features that help explain what the diagram depicts.
LESSONS LEARNED
Diagrams are useful in that they include useful information and exclude useless information often found in photos. They draw your attention to the issue at hand and keep the deponent focused on what matters. They can play a significant role in supporting and winning your case.
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SECTION 03 USING EXHIBITS