Deposition Tips

Evan Schaeffer offers some good tips on taking and defending depositions. The Illinois Trial Practice Weblog: Depositions

"Defending Depositions: Correcting Your Client's Unintentional Errors" (March 15) addresses what to do when you client misspeaks -- e.g., saying "May" when it should be "March," or forgetting to mention someone who was present during an event.

"When Taking Depositions or Making Oral Arguments, Beware Pronoun Soup" (March 6) reminds us to fill in names and not use vague pronouns repeatedly. Which of the following would be better cross-examination?

• When I asked "Did you see Ms. Hennessey sign the contract?" you answered "Yes," didn't you?
• When I asked "Did you see her sign the contract?" and you knew I was talking about Ms. Hennessey because here it is, um, uh, six pages back in the transcript, you answered "Yes," didn't you?

And those are just Schaeffer's two most recent deposition tips. There are dozens more!

Filed in: depositions, tips, Illinois-Trial-Practice-Weblog, Schaeffer