Page 74 - FDCC Deposition Drills

A FEW QUESTIONS TO DISCUSS
How should one address an attorney who interrupts or coaches?
How do you shut down such behavior?
What tone and approach are most effective when dealing with such behavior?
Deposition Drills How to Teach Deposition Skills
Handling Interruptions
Another weapon in the arsenal of the unscrupulous opposing counsel is to interrupt your questions, give speeches or make statements to coach their witness. Be prepared to deal with these scenarios when they arise.
EXPLANATION
Participants learn how to deal with an attorney interrupting their questioning.
EXERCISE
Explain the various ways an attorney can interrupt a deposition and then provide various approaches on how best to deal with it. Role play and interrupt participants’ deposition questioning and encourage them to try different approaches to deal with it.
LESSONS LEARNED
This exercise teaches participants how to deal with attorneys trying to coach deponents. If an attorney sees a deposition going south, they may go beyond deposition decorum and say and do things to help a witness recover. Knowing what to do in response can ensure one preserves favorable testimony and prevents a witness from being coached.
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SECTION 05 OBSTREPEROUS OPPOSING COUNSEL