Thoroughness is often the focus in preparing for depositions. Of course, ensuring your exhibits and planned areas of inquiry cover all potential aspects of trial testimony is very important. But another important facet of deposition preparation is efficiency.
Indeed, California recently fell in line with federal courts in mandating seven-hour depositions in many instances. In this context, efficiency can mean the difference between a thorough and an incomplete deposition. And, contrary to common perceptions, efficiency is much less a product of fast-talking questioning and more a product of non-innate skills of preparation and approach. The following five tips will help you improve the efficiency of your depositions, which might just facilitate the completeness of your questioning.
Have exhibits selected, copied and ready to be marked
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