Page 63 - FDCC Deposition Drills

Deposition Drills How to Teach Deposition Skills
Funneling
An effective cross examination technique is going from general to specific, from broad to narrow, from large to small. This exercise addresses how to use funneling as a cross examination technique.
EXPLANATION
Participants learn how to start with broad topics and funnel into narrow ones.
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 what is funneling and how to do it. Have the participants question you (as you role play the witness) and have them use the funneling technique.
LESSONS LEARNED
A funnel is a great visual for effective questioning – going from broad to narrow. Along the way, you close escape hatches and doors for the witness to lock them into positions favorable to your case. Funneling guides the witness to the end of a long narrow hallway with no exit. It provides a pathway to an inescapable result that benefits the questioner.
A FEW QUESTIONS TO DISCUSS
Why is it important to engage in funneling?
How do you funnel questions?
What do you achieve by using a funneling approach?
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SECTION 04 CROSS EXAMINATION