When preparing to depose the plaintif, begin with the end in mind – the goal of the case. What is the ultimate objective, not just in the deposition, but for the lawsuit? To win, you may say, but …

Explain the deposition process and purpose to the deponent, including the persons expected to attend and the usual admonishments on deposition procedures offered at deposition by the …

Discuss how to properly advise and prepare your client or witness for a deposition. What constitutes improper advice and/or preparation? Discuss professional ways to handle a …

Think in paragraphs -- identify a topic, ask a general question, then ask who, what, where, when, why and how, then use a closing question -- "Anything else you can think of?"! In general, …

Here’s a ten-step checklist to help you avoid common pitfalls that can hurt a deposition. 1. DEPoSE or DoN’T DEPoSE? Is the deposition even necessary? Might the deponent reveal …

The parameters of a Rule 30(b)(6) deposition may vary greatly from case to case, but the following categories of deposition questions and topics will serve as a good outline when …

The following is a list of standard questions to use at the beginning of a deposition, the purpose of which is to limit the deponent's ability to evade impeachment later in the

a. Deposition- although not occurring in the courtroom, a formal judicial proceeding at which sworn testimony is taken from a witness in the form of a question-and-answer session. As a …

What Is A Deposition? A deposition is an oral question and answer session at which a witness or deponent provides sworn, oral testimony or answers in response to questions posed by …

For Mr. Markowitz’ complete DVD/CD course on Deposition Techniques: Strategies, Tactics and Skills visit www.trialguides.com/media/deposition-techniques. Each deposition and each …

In essence, a deposition is your oral testimony taken under oath by a court reporter in response to questions by other attorneys, and in some cases, by an attorney representing you. The …

Below are tips for maximizing the impact of depositions at trial, both for depositions you are taking and those you are defending. Treat it like a conversation.

answers your questions during the depo-sition? Knowing in advance what to expect can help you plan your strategy and can help you anticipate (and prepare for) prob-lems that might arise.9 I …

If you find this article helpful, you can learn more about the subject by going to www.pli.edu to view the on demand program or segment for which it was written. 1. Noticing the Deposition …

Deposition Outline/Questions of Mr. Lutz -- SAMPLE I. General/Overview Questions of Mr. Lutz (Starting open ended – Basic Structure) A. How did you use Lot 19, 20, 21, and 22? (#1 – …

Preparation is the key to handling depositions with aplomb. Here is a simple checklist of things to consider when preparing for a deposition. Send a letter to opposing counsel just after serving …

In New York, in a medical malpractice deposition, you must ask opinion questions. The doctor- as a defendant is required to answer ‘expert’ questions and give answers about his medical …

In order to help you prepare for your deposition, you need to understand that there is a great difference between a deposition and a trial. This deposition is going to be a one sided affair. It …

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