Before the Session
During the Session
- What logistics do you need to take care of before taking a deposition?
- What are some things you can do to get your deposition off to a good start?
- What tone will you try to establish with the witness to start the deposition?
- What should you be doing while the witness is giving an answer?
- What would you do if one of your questions isn’t working?
- How would you handle a witness that says “I don’t recall” a lot or claims not to understand basic terms?
- How would you handle a witness that won’t admit anything?
- What would you do with an aggressive opposing counsel?
- What should you do when you think you’re done asking questions?
- 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
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