Deposition Checklists & Strategies

by Evan Schaeffer

Fast and Thorough Deposition Preparation

Creating an outline is the most efficient way of formalizing your preparation for a deposition. 

Use the outlines and pattern questions in Deposition Checklists & Strategies to avoid omissions, improve your advocacy, and handle unfamiliar areas with confidence.  You receive:

• Underlying law.  Each chapter begins with a summary of the substantive law at issue.  Also included is an analysis of common defenses.

• Deposition outlines.  Each chapter contains several full-length deposition Q&A sections organized by issue, based on common fact patterns, and directed at specialized deponents like experts, corporate representatives, and treating physicians. The book’s
  questions are easy to mix and match with your own.

• Commentary.  Thorny or common issues are annotated with practice-proven alternatives and solutions. 

• Bonus outlines.  Thumbnail checklists that contain themes and issues rather than question-and answer dialogue are provided for less-common deponents.

• Related discovery forms.  Complaints, interrogatories, requests for admissions, requests to produce, and more finish each chapter.    

• Practice tips.  Sprinkled through each pattern deposition is practical advice learned from hundreds of depositions.

Detailed Q&A

Each pattern deposition outline contains extensive questions and selected answers for the issues most likely to arise. Troublesome answers are annotated with commentary and follow-up questions. Here is an example of the subjects covered in one sample deposition:

Defendant Driver in Auto Case

1. Thumbnail Outline with Issues and Themes

2. Preliminary Questions
   Introductory Questions
   Witness' Background
   Witness' Preparation for the Deposition
   Witness's Relationship to Other Parties and Witnesses

3. The Collision
   Events Leading Up to the Collision
   Central Events
   After the Collision
   Driving Experience and Licensure

4. Defendant’s Condition on Day of Collision
   Defendant’s Activities on the Day of the Collision
   Estimates of Times
   Establishing Fatigue
   Alcohol and Drugs

5. The Vehicles
   Condition of the Deponent’s Vehicle Before the Collision
   Condition of the Vehicles After the Collision
   Lack of Damage as Evidence of Negligible Force

6. Traffic Tickets and Plaintiff’s Negligence
   Traffic Tickets
   Plaintiff’s Contributory Negligence

7. Admissions, Witnesses, and Statements
   Admissions
   All Witnesses to the Occurrence
   Knowledge of Conversations
   Formal Statements
   Informal Statements and Interviews
   Conversations About the Accident or the Lawsuit

8. Closing
   Photographs and Diagrams
   Closing Questions

Updated annually.  ISBN 1-58012-114-4. Price: $99.00

K6

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Related Titles:

Guerrilla Discovery
Handling Federal Discovery
How to Prepare for, Take, and Use a Deposition

Model Interrogatories
Triple-Threat Discovery Forms