Page 60 - FDCC Deposition Drills

A FEW QUESTIONS TO DISCUSS
Why is it important to exhaust a topic? How do you exhaust a topic?
What do you achieve by exhausting a topic?
Deposition Drills How to Teach Deposition Skills
Exhaust Each Topic
Sometimes we don’t explore a topic thoroughly in deposition or we don’t secure all the admissions we can because we don’t exhaust each topic with a witness. This exercise addresses how to exhaust each topic with a witness.
EXPLANATION
Participants learn how to exhaust a topic with a witness before moving onto the next topic.
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. Have the participants question you (as you role play the witness) and have them take turns until they’ve exhausted all the questions that can be asked about a given topic.
LESSONS LEARNED
This exercise teaches to squeeze the marrow out of every topic to score as many points as possible with a jury.
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SECTION 04 CROSS EXAMINATION