Page 80 - FDCC Deposition Drills

Deposition Drills How to Teach Deposition Skills
The Rules
We all share with our clients what the rules of deposition are. Tell the truth. Answer only the question asked. Wait two full seconds before answering a question. Interrogate the interrogator. Etc. Some attorneys have a handful of rules. Some have many more. It’s important to think through what your rules are and how to share them with the client.
EXPLANATION
Participants learn the deposition rules to share with clients and how to share them.
EXERCISE
Write down all the deposition rules you share with clients. Ask others at your firms for their rules. Share the rules with the participants, discuss how to share and explain them to clients and have participants run through the rules with you.
LESSONS LEARNED
This exercise teaches participants what the rules of the road are for depositions and how to explain them to clients. Participants learn not only, for example, to tell clients to only answer the question asked, but to run through examples with clients so they understand the rule and apply it.
A FEW QUESTIONS TO DISCUSS
What are the typical rules of the road?
Why are these considered to be the rules of the road? How do you explain these rules to the client?
How do you teach these rules to the client?
SECTION 06 DEFENDING DEPOSITIONS
74
©2021 Federation of Defense & Corporate Counsel