The Top 10 Killer Deposition Questions

The Top 10 Killer Deposition Questions

From David Newdorf's Blog

One of the prime reasons to spend the time and money to depose an adverse witness is to gather impeachment material. Other than hiring a private investigator to delve into the witness’s past, the deposition is the most effective tool in the lawyer’s arsenal for uncovering dirt and chipping away at credibility. That includes attacking an eye-witness account, challenging an unfavorable opinion, exposing bias, and undermining believability.

Yet most lawyers don’t ask all of the basic, open-ended questions that could help achieve their impeachment goals. In every deposition, there are questions tailored to the facts of the case, whether it is a business dispute or personal injury claim. But many (if not all) of these “killer” questions should be asked of adverse witnesses in every type of case. Many times you will strike out. That’s okay, because when you do connect with one of these questions, the result is likely to be a solid base hit – and occasionally a grand slam. The answers to these basic questions can be so damaging to the opponent’s case that the litigation will end on terms favorable to your client. And isn’t that the goal?

The Top 10 Killer Deposition Questions
http://www.newdorf.com/litigation-tips/top_ten_killer_deposition_questions