Tips & Tactics
Timing Depositions ...
Foolish lawyers (those who don't care if they win or lose as long as they get their clients to pay for their time) often take depositions too early!
Don't make this mistake!
Lazy lawyers take depositions before they know enough about the underlying facts to ask effective questions of the deponent witness.
Since you usually get only one chance to depose a witness, you need to know as much as possible before you take depositions.
Serve some written discovery requests first. Use subpoenas and requests for production to get documents and things. Use requests for admissions and interrogatories to fill in the blanks.
Then, when you have your witness in the chair under oath, you can hand her things and documents (you wouldn't otherwise have had) and ask questions about them. You can review responses you got to interrogatories and requests for admissions, requiring the deponent to explain those responses under oath.
Of course it does ... like everything Jurisdictionary teaches!
The typical lawyer (who doesn't care if he wins or loses so long as he gets paid) is too lazy to draft written discovery requests and get responses before depositions. It's much easier to notice a witness for deposition then sit at the table and ramble on for several hours. I've known lawyers who could spend days in depositions, billing their client for every hour, when a little bit of pre-deposition discovery (subpoenas, requests for production, requests for admissions, and interrogatories) would prepare them to take depositions effectively and get case-winning facts into evidence quickly, instead of wasting their clients' hard-earned money to finance fishing expeditions.
Don't be foolish.
Let Jurisdictionary show you how to prepare for depositions so you can get effective evidence at the proper time.
Learn how to time your evidence discovery wisely.
It's easy ... when you proceed step-by-step!
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