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The Inexperienced Lawyer’s
Checklist For Depositions
FROM
754-367-1802
We’ve in been the court reporting and
deposition industry for years serving the Palm
Beach, Broward and the Miami-Dade areas for
years.
Here’s a few tips on depositions from the team at Honorable Court Reporting.
A lawyer’s goal when conducting a deposition
should be moving the case to a verdict or
settlement. This is done by making an evaluation of
the witnesses, what they know and how it will affect
the witness as far as a favoring settlement. It’s
extremely important for newer lawyers take note and
do an adequate preparation for a deposition so that
this time is used wisely.
The last thing that you want at the trial is a surprise
smacking you in the head. A successful deposition
will give you the tools necessary to fight for your
client during the trial. One area that in-experienced
attorney’s neglects is their use of time.
Assuming that a deposition has a specific and
dedicated time frame is not a good idea. The less
seasoned lawyer needs to remember that a
deposition can take more than an hour to conduct.
In certain situations, you can predict that the
deposition could take up to a few days to complete.
A common mistake for many law grads is that they
neglect the time.
Another area that is often difficult to deal with is the
witness. Many people that are present and may be
deponents will often ‘claim or black out’ during a
deposition. By asking them, “Is this all you can
remember when he asked you to do xyz” is there
anything I can show you that will help you recollect
the information (be specific).
A Form objection is the one that challenges the
manner in which the question is posed. This is a trial
technique that must be practiced and can be very
complex because they do not require hearsay,
objections or evidence. You need to take extra
precaution here.
What’s your purpose in taking a deposition? This
should be one of the first elements you should
consider prior to moving forward. What information
are you looking for? Is this for trial testimony or are
you seeking specific information. All questions to
prepare for that will help you get the most out of the
time with the deponent. Don’t forget to take note of
why the witness is ideal to defeat a pretrial or
judgment motion?
Deposition Blueprint:
Did you write your series of questions?
How will you organize and prepare?
Background: Did you start with their background, personally? Are they an expert
witness and did you get their resume to determine their credibility?
Identification of Documents: Facts, Documents, Signatures and authentications
are addressed.
Chronological List of questions a timeline to avoid objections: Are you asking a
timeline for the witness to answer and elaborate on?
Start with least controversial examination: Don’t grill the witness right out the
gate. Take the time to make the conversation light in the beginning and lead up to
more pressing questions later. Warm up to each other.
“Remember to bring a copy of the deposition
subpoena, and any witness fees that you might be
obligated to give to the witness. Also, bring a
business card to give to the court reporter so that
he or she can see how to spell your name, and so
that they have contact information for you.”
Remarks author Russell H Ando. Good advice to
make note of.
This and more helpful information can be found on
our website. Keep in mind each blog is prepared
with you in mind. If you’d like to see information on
a particular topic, we’d like to hear about your
ideas. You can share your questions, and
suggestions by visiting
http://miamicourtreportingservices.com/
Here at Honorable Reporting, we are totally committed to exceeding the expectations of
our clients. We believe strongly that our job is to make your job easier and we work very
hard to off load as much of your workload as possible. Our convenient scheduling
options for local or national depositions and the use of the latest technology for
transcripts, exhibits and video processing are all offered to streamline and simplify the
deposition and trial preparation process.
Call or Contact Us Today & Receive 50% Off Your First Deposition
Appearance Fee.
Let Us Show You Just How Great We Are!!
Deposition services miami-dade, Court Reporting Miami Dade
court reporter Ft Lauderdale,Transcription Service Fort
Lauderdale,court services Miami
754-367-1802

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The inexperienced lawyer’s checklist for depositions

  • 3. We’ve in been the court reporting and deposition industry for years serving the Palm Beach, Broward and the Miami-Dade areas for years. Here’s a few tips on depositions from the team at Honorable Court Reporting.
  • 4. A lawyer’s goal when conducting a deposition should be moving the case to a verdict or settlement. This is done by making an evaluation of the witnesses, what they know and how it will affect the witness as far as a favoring settlement. It’s extremely important for newer lawyers take note and do an adequate preparation for a deposition so that this time is used wisely.
  • 5. The last thing that you want at the trial is a surprise smacking you in the head. A successful deposition will give you the tools necessary to fight for your client during the trial. One area that in-experienced attorney’s neglects is their use of time.
  • 6. Assuming that a deposition has a specific and dedicated time frame is not a good idea. The less seasoned lawyer needs to remember that a deposition can take more than an hour to conduct. In certain situations, you can predict that the deposition could take up to a few days to complete. A common mistake for many law grads is that they neglect the time.
  • 7. Another area that is often difficult to deal with is the witness. Many people that are present and may be deponents will often ‘claim or black out’ during a deposition. By asking them, “Is this all you can remember when he asked you to do xyz” is there anything I can show you that will help you recollect the information (be specific).
  • 8. A Form objection is the one that challenges the manner in which the question is posed. This is a trial technique that must be practiced and can be very complex because they do not require hearsay, objections or evidence. You need to take extra precaution here.
  • 9. What’s your purpose in taking a deposition? This should be one of the first elements you should consider prior to moving forward. What information are you looking for? Is this for trial testimony or are you seeking specific information. All questions to prepare for that will help you get the most out of the time with the deponent. Don’t forget to take note of why the witness is ideal to defeat a pretrial or judgment motion?
  • 10. Deposition Blueprint: Did you write your series of questions? How will you organize and prepare?
  • 11. Background: Did you start with their background, personally? Are they an expert witness and did you get their resume to determine their credibility? Identification of Documents: Facts, Documents, Signatures and authentications are addressed. Chronological List of questions a timeline to avoid objections: Are you asking a timeline for the witness to answer and elaborate on? Start with least controversial examination: Don’t grill the witness right out the gate. Take the time to make the conversation light in the beginning and lead up to more pressing questions later. Warm up to each other.
  • 12. “Remember to bring a copy of the deposition subpoena, and any witness fees that you might be obligated to give to the witness. Also, bring a business card to give to the court reporter so that he or she can see how to spell your name, and so that they have contact information for you.” Remarks author Russell H Ando. Good advice to make note of.
  • 13. This and more helpful information can be found on our website. Keep in mind each blog is prepared with you in mind. If you’d like to see information on a particular topic, we’d like to hear about your ideas. You can share your questions, and suggestions by visiting http://miamicourtreportingservices.com/
  • 14. Here at Honorable Reporting, we are totally committed to exceeding the expectations of our clients. We believe strongly that our job is to make your job easier and we work very hard to off load as much of your workload as possible. Our convenient scheduling options for local or national depositions and the use of the latest technology for transcripts, exhibits and video processing are all offered to streamline and simplify the deposition and trial preparation process.
  • 15. Call or Contact Us Today & Receive 50% Off Your First Deposition Appearance Fee. Let Us Show You Just How Great We Are!! Deposition services miami-dade, Court Reporting Miami Dade court reporter Ft Lauderdale,Transcription Service Fort Lauderdale,court services Miami