Page 81 - FDCC Deposition Drills

Deposition Drills How to Teach Deposition Skills
Mock Deposition
The best way to prepare a client for deposition is to subject her to a mock deposition, wherein you ask her the tough questions, have her answer them and then help her work on her answers, both substantively and stylistically. After a client is deposed you want her to say that your mock deposition was much tougher and prepared her for the real thing.
EXPLANATION
Participants learn how to conduct a mock deposition.
EXERCISE
Explain how you conduct a mock deposition and conduct one wherein you question the participants and show them how to question a client in a mock deposition setting. After you show them how it is done, have them conduct mock questioning of you.
LESSONS LEARNED
This exercise teaches how to question a client so as to recreate the experience of being deposed to prepare her for the real thing.
A FEW QUESTIONS TO DISCUSS
Why is conducting a mock deposition an important part of deposition prep? How should you conduct a mock deposition?
What types of questions should you ask?
How should you ask them?
How tough should you be with the client during the mock cross?
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SECTION 06 DEFENDING DEPOSITIONS