Page 41 - FDCC Deposition Drills

Deposition Drills How to Teach Deposition Skills
Delving Deep
When examining a topic or issue with a witness, getting to the bottom of that topic or issue takes time, patience, effort and many, many questions. Covering the water front, delving deep, and exhausting all the questions that can be asked requires you to know your case, the documents, the facts and the witnesses and pressing and pushing and exploring an issue or topic with a witness.
EXPLANATION
Participants learn how to exhaust questioning of a deponent regarding a given issue or topic.
EXERCISE
Select a witness you deposed who had a lot of information and knowledge to share and put you through your paces to extract that information and knowledge. Share your experience with the participants, play the role of that witness and have them conduct a thorough examination of you. Whenever a participant runs out of questions, provide suggestions of other lines of questioning to pursue.
LESSONS LEARNED
Thisexerciseteacheshowtofullyexploreatopicorissue. Runninganissuetoground takes time, effort and creativity. There are different ways and approaches to get a witness to reveal everything they know. By conducting this exercise in a small group, the participants can observe how others try to delve deep with a witness.
A FEW QUESTIONS TO DISCUSS
How do you thoroughly explore a topic or issue with a deponent? How do you deal with an evasive deponent?
What are different ways to secure all the information a witness has?
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SECTION 03 GATHERING INFORMATION