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What kind of case and what kind of witness (current or former client employee, third party, older, younger, senior, junior, etc)? Also are you leading the witness prep?
you should print out the proper objections for your jurisdiction and have them with you. no shame in that
F
Defending is harder than taking. First rule is remembering that everything the witness looks at to refresh his recollection is discoverable. Prep should be mostly verbal. As noted above, in most jurisdictions all objections are preserved except for form of the question and privilege. Only if something is outrageously irrelevant do you object on relevance. Otherwise objecting to form, asked and answered, and/or lack of foundation is about it. Depending on the attorney, you may or may not be able to get away with "speaking objections" -- that is, narrative objections that give info to the witness. For instance, if the examiner asks a repeated question, the proper objection is "Objection. Asked and answered." The speaking objection version would be "Objection. Asks and answered. Clearly testified that . . ." You can't do that at trial and can't get away with much if any of it at a depo. Generally you do not instruct the witness not to answer unless privileged information is sought. Tell your witness not to answer until you have time to object and that if object to form or lack of foundation, that's a signal that it's a trick question. One could object on either grounds to "When did you stop beating your wife?" Not sure about depo defense books. Thomas Maury's Trial Techniques book is great for the beginner on things like laying a foundation to get an exhibit in or an expert blessed. If you have not already, it would be good to watch a few or at least read some transcripts. Good luck!