Page 39 - FDCC Deposition Drills

Deposition Drills How to Teach Deposition Skills
Soliciting Information
One of the purposes of the deposition is to learn what a deponent knows about your case. Learning to follow up with a deponent, explore topics, press a witness and seek details ensures you leave a deposition knowing what a witness knows and avoid being surprised by her at trial.
EXPLANATION
Participants learn how to extract as much information as possible from a deponent.
EXERCISE
Think about a witness you deposed who had crucial information but was hesitant to share it in deposition. Play the role of the witness and have participants question you. Push them to keep asking questions, to keep exploring, to keep pushing you to provide more and more information.
LESSONS LEARNED
This exercise teaches participants to keep asking questions, exploring the full range of knowledge, understanding and memory of witnesses. Learning to listen to a deponent, what they say (and what they don’t), studying their body language, and pushing them to reveal everything they know.
A FEW QUESTIONS TO DISCUSS
How do you get a deponent to reveal what they know?
What questions can you ask to explore the full range of knowledge of a deponent?
How do you fully explore a topic with a deponent? What follow up questions should you ask? How should you ask them?
What television interviewers are effective to get guests to share their stories? How do they do it?
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SECTION 03 GATHERING INFORMATION