Page 49 - FDCC Deposition Drills

Deposition Drills How to Teach Deposition Skills
Asking One Fact Per Question
The less information you ask a witness, the more basic your questions, the more likely you’ll secure a favorable response. Learning how to ask one fact per question and only one fact, extends a favorable a cross examination and prevents a witness from taking issue with your questions and providing unfavorable responses. This exercise addresses how to ask one fact per question.
EXPLANATION
Participants learn to ask one fact per question.
EXERCISE
Identify a witness you cross-examined in deposition and describe the case and the role of the witness in the case to the participants. Explain how to ask only one fact per question and have the participants question you (as you role play the witness) by asking one fact per question. Show them how to break each question into small, more discrete questions.
LESSONS LEARNED
Asking one fact per question forces one to turn every question into an atom sized question. If a question is a molecule sized question, it’s too big. It can be broken down even further. Single fact questions are difficult to evade.
A FEW QUESTIONS TO DISCUSS
Why is it important to ask one fact per question? How does one ask one fact per question?
What do you achieve by asking one fact per question?
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SECTION 04 CROSS EXAMINATION