Scott Himes Taking Depositions in Discovery for Effective Cross-Examination at Trial
Preparing for and taking a deposition means playing the long game. What you do at the deposition arms you for cross-examination at trial—as long as you handle the deposition with trial cross squarely in mind.
September 30, 2021 at 11:00 AM
13 minute read
Frequently when defending my client at a deposition, I have been astounded by the opposing counsel's questioning. I find myself wondering "how does counsel possibly think these questions will get any answers to help at trial?" "Doesn't counsel realize that the testimony my client is giving should be the stuff of cross-examination in the courtroom, where it matters much more than in the deposition room?" Failing to ask your questions the right way at deposition can leave you without the ammunition you need to cross-examine that person effectively at trial.
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