Page 64 - FDCC Deposition Drills

A FEW QUESTIONS TO DISCUSS
Why is it important to show a witness’s bias? How do you show a witness’s bias?
What do you achieve by showing a witness’s bias?
Deposition Drills How to Teach Deposition Skills
Showing Bias
Establishing a witness’s bias goes a long way to undermine his credibility. This exercise addresses how to show a witness’s bias.
EXPLANATION
Participants learn how to show a witness’s bias.
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 the importance of showing bias and all the ways a given witness may be biased. Explain how you’ve exposed bias in questioning of witnesses in deposition. Have the participants question you (as you role play the witness) and have them expose your biases as a witness.
LESSONS LEARNED
Most every witness has some form of bias. Drawing out that bias and showing it to the jury goes a long way to inoculate and damage testimony.
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SECTION 04 CROSS EXAMINATION