Litigators - any tips for preparing questions for depositions/examinations for discovery?

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Start with the pleadings. Think about how the witness fits into each of those claims, counterclaims, and defenses. If the witness has any production related to her, look at those documents.

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1. Review pleadings 2. Review file notes 3. Review documents exchanged between parties 4. Ask other attorneys in your firm for templates of questions on similar matters Depends on what type of case you’re doing

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I always write out like a flow chart of how I want the depo to go. Think through the questions. Know that I can go off script if sometbing piques my interest. My boss does this (and I do too): finds allegations in the complaint and says do you know of any facts to support x allegation. Usually does this with critical witnesses and plaintiffs.

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Yesss I love the idea of the allegations! Didn’t think of that!

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It went well I think! Thanks for the suggestions.

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