Tips and strategies for taking a deposition, including starting the deposition off right, asking questions effectively, dealing with a difficult witness or opposing counsel, and ending the deposition well.
Discussion of how to conduct a witness prep meeting, focusing on making the witness comfortable with how the deposition will work, explaining how depositions differ from ordinary conversation, and giving the witness tips on how to answer questions.
Discussion of how to conduct a witness prep meeting, focusing on preparing the witness for the substantive aspect of the deposition—reviewing the substantive topics and potential exhibits with the witness, and conducting mock questioning.
Strategies and procedures for defending a corporate witness, including what to do when your witness doesn’t know the answer, questions outside the scope of topics, and rehabilitating the witness through re-direct.
Rules and tips for selecting the corporate witness; how a corporate witness’s role differs from a fact witness; assembling materials for corporate witness prep; reviewing the topics with the witness; and tips for reviewing the topics and practicing Q&A with a corporate witness.