Page 79 - FDCC Deposition Drills

Deposition Drills How to Teach Deposition Skills
The Client Speech
Each of us lawyers has a speech we give our clients to prepare them for depositions. Each of our speeches is different, but they typically encompass an explanation of depositions, what to expect at deposition, the role of the opposing counsel, one’s role, the rules of the road, the types of questions to expect and what deposition preparation will entail. It’s important to develop one’s speech and have it ready. It’s a speech that gets tweaked depending on the case and the client.
EXPLANATION
Participants learn what to include in their deposition preparation “speech” to the client.
EXERCISE
Tell the participants what you include in your speech to the client. Also share what you know others share in their speeches. Explain the purpose of the various aspects of your speech. Have each participant provide one part of the speech so they become accustomed to delivering the speech.
LESSONS LEARNED
This exercise teaches participants what to include in their deposition preparation speech to the client and how best to deliver it. The speech allows you to walk the client through what to expect and starts indoctrinating her about her role at deposition.
A FEW QUESTIONS TO DISCUSS
Why is it important to give the client the speech?
Howcanoneindoctrinatetheclienttobetterunderstandherroleandher importancein the case?
What are the different aspects of the speech?
How do you modify the speech according to the case or the client?
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SECTION 06 DEFENDING DEPOSITIONS