Page 52 - FDCC Deposition Drills
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A FEW QUESTIONS TO DISCUSS
Why is it important to use common words when questioning a witness? What is a common word and what isn’t?
What do you achieve by using common words?
Deposition Drills How to Teach Deposition Skills
Using Common Words
We lawyers have large vocabularies. We have to leave our big words at the door when questioning a witness. This exercise addresses how to use common words.
EXPLANATION
Participants learn to use common, basic terms and words when questioning a witness.
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. Discuss a list of words to avoid while questioning witnesses. Discuss words often used (but shouldn’t because they’re too long or complex) and discuss appropriate alternative words. Have the participants question you (as you role play the witness) using only common words in the questions.
LESSONS LEARNED
Big words can be saved for law review articles and scholarly pieces. For juries, let’s stick to common, every day words.
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SECTION 04 CROSS EXAMINATION
