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Prep like you are the only one deposing the person. Make sure you grasp the critical issues. Make sure you know what information your adjuster is looking to evaluate the case.
Figure out what key thing you need from the depo and make sure it’s in the transcript, o like to write that on the margin of my notepad. I also have an outline of all my questions, but I do first party ID, no one even does cross unless the case is going to trial.
I’m about to take an expert witness this week and I’m going to use chat gpt for the first time to assist with the outline.
Best advice I got about a depo.: be curious. Ask questions and see what story you get. It may be different than how you have framed the case.
Associate Attorney chatgpt wasn’t very good. It gave me a long list of areas of deposition that I already knew to explore and are part of any standard expert depo. Maybe my prompts weren’t good enough to yield good results. ..