Every litigator will conduct a deposition at some point in his or her career. Depositions are a chance for the litigator to obtain favorable (or unfavorable) evidence to use as part of the overall trial strategy. To quote Paul Gordon, however, “Depositions are one of the several points of friction between the science of practicing law and the art of practicing law. Understanding depositions is an essential tool for every litigator.”
Nationally renowned speaker David “Dave” Markowitz will be at the CLE offices on Wednesday, December 11, 2013, to teach about deposition strategies and techniques. He will share ten important goals for the litigator to accomplish in the deposition, including how to avoid undesirable results. Some of those goals are outlined here:
- Each deposition question should be aimed at accomplishing the desired result – the deposed witness should be questioned on relevant facts in order to create admissions to use at trial.
- Never attempt to accomplish improper deposition goals, such as deliberately trying to incur expense for the opponent.
- Determine what the big questions are and ask them. If they are answered, they will directly accomplish a major goal.
- Identify lying witnesses. Video record the deposition to visually demonstrate untruthfulness.
- Be thorough – decide which goals are the most important and spend the most time on these, while not neglecting points that are less important but will still help accomplish your goals.
If you are a litigator, or any attorney who conducts depositions, do not miss Dave Markowitz’s program on Wednesday, December 11. Click here to register or click the links below.