Cross-Examination for Depositions
Cases are often won or lost at the discovery stage, and knowing how to cross-examine deponents is an essential skill for all litigators. Cross-Examination for Depositions gives you the tools you need to maximize your effectiveness at depositions.
The authors show you how to focus on the "theory of the case" and prepare lines of questioning that support that theory. Following the authors' preparation guidelines will afford you a major advantage, before a deposition even begins.
Difficult witnesses can challenge even the most experienced deposing counsel, and the authors provide numerous suggestions on how to deal with scenarios involving difficult witnesses.
The authors emphasize the technique of using cross-examination constructively, to elicit facts from opposing witnesses to further your own theory of the case, as opposed to merely attacking your opponent's theory of the case. This technique, first introduced by Larry Pozner and co-author Roger Dodd in the classic work Cross-Examination: Science and Techniques, is devastatingly effective.
Numerous examples of deposition testimony are woven throughout the chapters. These examples clearly illustrate the points made in the book.
Table of contents
Chapter 1: Introduction
Chapter 2: Purposes of Depositions
Chapter 3: Preparing for the Deposition
Chapter 4: The Three Rules of Cross-Examination During the Deposition
Chapter 5: Chapters
Chapter 6: Chapter Sequences
Chapter 7: Constructive Cross-Examination at Depositions
Chapter 8: Advanced Skills
Chapter 9: Documents at Depositions
Chapter 10: Objections at the Deposition
Chapter 11: Practical Considerations
Chapter 12: Ethical Considerations