Page 45 - FDCC Deposition Drills

Deposition Drills How to Teach Deposition Skills
Other Sources of Information
It is important to not only learn what a witness knows about a case but secure the names of other witnesses who may have information about the case and learn of any documents that may be relevant to the case. When we take depositions, we most explore all the other sources of information available to consider pursuing through other depositions, witness interviews, subpoenas for records, etc.
EXPLANATION
Participants learn to explore all the witnesses and documents a deponent may be aware of and which are relevant to the case.
EXERCISE
Think about a witness you deposed who was aware of other relevant witnesses and aware of relevant documents. Provide participants an overview of the case and witness and have them question you, soliciting information about relevant witnesses and documents.
LESSONS LEARNED
This exercise teaches one to pursue all avenues of information. A given deponent may not know much or be of much help, but may direct one to other valuable sources of information.
A FEW QUESTIONS TO DISCUSS
Who are the possible witnesses in your case?
What are the relevant documents in your case?
Who knows what in your case?
What can you do to track down relevant witnesses and documents?
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SECTION 03 GATHERING INFORMATION