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Facilitator Guide

Taking a Corporate Deposition

What’s covered

  • Differences between corporate and fact witnesses
  • Confirming the corporate witness’s understanding of their role
  • Questions about the corporate witness’s prep
  • Asking the corporate witness substantive questions  
  • How to handle “I don’t know” answers
  • Asking a corporate witness about documents
  • Seeking more deposition time of a corporate witness

Before the session

Prepare the Attendees

Send the attendees an invitation for the session. Include this link, which has the videos and exercise they’ll need to prepare.

https://www.hotshotlegal.com/discussions/taking-a-corporate-deposition/attendee

Prepare Yourself

Watch the videos and read the exercise so you’re familiar with the Hotshot material.

During the session

Part 1: Knowledge Check

Ask attendees these questions to ensure they understand the topic:

  • What are some differences between deposing corporate and fact witnesses?
  • What are some of the first things you want to accomplish at a corporate witness’s deposition? 
  • In what capacity does a corporate witness testify?
  • How would you use documents at a corporate deposition?
  • What do you do if the corporate witness doesn’t have sufficient knowledge of important topics?

Part 2: Group Exercise

Lead a group discussion based on the exercise. To encourage collaboration, divide the attendees into groups to discuss the exercise, then have a representative from each group summarize their views to the larger group. Call on people to share their thoughts and ask others to respond.

Tip for remote sessions: use your web conferencing system’s breakout room feature to divide people into groups.

Part 3: War Stories and Firm Specifics

Share your own experiences and guidance, including:

  • Anecdotes and war stories (e.g., about a near-disaster or a tough negotiation)
  • General practice tips (dos and don’ts)
  • Firm-specific guidance and practices

After the session

To continue their learning, attendees can check out related courses in Hotshot’s Depositions topic.