Upload
victoria-pynchon
View
1.259
Download
1
Embed Size (px)
DESCRIPTION
For the first Art of the Deposition Class at Solo Practice University.
Citation preview
+
The Art of the Deposition
The Basics
Victoria Pynchon, Esq.
+Getting Ready
Why am I taking this deposition? Info Ammo Admissions Dirt
How do I prepare? Complaint, answer, interrogatories, other testimony Documents Jury instructions
Victoria Pynchon, Esq.
+Getting Started
The Court Reporter Knows More than You Do s/he doesn’t “strike” anything from the record s/he will do what you ask (within limits) s/he will tell you preferences in advance
Swearing the Witness
Explaining the Procedure Setting witness up for impeachment Establishing authority/relationship
Victoria Pynchon, Esq.
+The Funnel Technique
Victoria Pynchon, Esq.
Who, what, when, where
how, describe explain
FOLLOW UP What do you meanGive details
FILL INDid you? Was there? Have you? Did you ever?
EXHAUST What else? Is that everything?
RECAPAs I understand it . . . Is that right?Nothing more?
ADMISSIONSMake statements obtain agreement
THEORY TESTING
+Faulty Memory
Anything else that might help refresh memory Talk to anyone else Look at something else
Helping witness remember Seasons of the year How old children were Working for X or Y at the time
Standard practices and procedures
Habit and custom
Victoria Pynchon, Esq.
+Meetings and Conversations
How many times
Let’s talk about the first conversation Who was present How long did it last What were the subjects discussed Who talked about the first subject
What did Bob say What was the response Then what Anything more
Victoria Pynchon, Esq.
+Objections
Objections to pay attention to Foundation Back-filling foundation
Objections to ignore Those trying to throw you off Vague, ambiguous
Objections to object to Coaching the witness Interfering with questioning
Victoria Pynchon, Esq.
+Role plays
To be assigned
A and B teams to be formed
Students to confirm those who can participate live in Saturday morning interactive sessions
Victoria Pynchon, Esq.