Fast and Thorough
Deposition Preparation

   Creating an outline is the most efficient way of formalizing your preparation for a deposition. 

   Use the outlines and pattern questions in Deposition Checklists & Strategies to avoid omissions, improve your advocacy, and handle unfamiliar areas with confidence.  You receive:

1.   Underlying law.  Each chapter begins with a summary of the substantive law at issue.  Also included is an analysis of common defenses.

2.   Deposition outlines.  Each chapter contains several full-length deposition Q&A sections organized by issue, based on common fact patterns, and directed at specialized deponents like experts, corporate representatives, and treating physicians. The book’s questions are easy to mix and match with your own.

3.   Commentary.  Thorny or common issues are annotated with practice-proven alternatives and solutions. 

4.   Bonus outlines.  Thumbnail checklists that contain themes and issues rather than question-and-answer dialogue are provided for less-common deponents.

5.   Related discovery forms.  Complaints, interrogatories, requests for admissions, requests to produce, and more finish each chapter.    

6.   Practice tips.  Sprinkled through each pattern deposition is practical advice learned from hundreds of depositions.

Detailed Q&A

   Each pattern deposition outline contains extensive questions and selected answers for the issues most likely to arise.  Troublesome answers are annotated with commentary and follow-up questions.  Here is an example of the subjects covered in one sample deposition:

DEFENDANT DRIVER IN AUTO CASE

1. Thumbnail Outline with Issues and Themes

2. Preliminary Questions

   Introductory Questions

   Witness' Background

   Witness' Preparation for the Deposition

   Witness's Relationship to Other Parties and Witnesses

3. The Collision

   Events Leading Up to the Collision

   Central Events

   After the Collision

   Driving Experience and Licensure

4. Defendant’s Condition on Day of Collision

   Defendant’s Activities on the Day of the Collision

   Estimates of Times

   Establishing Fatigue

   Alcohol and Drugs

5. The Vehicles

   Condition of the Deponent’s Vehicle Before the Collision

   Condition of the Vehicles After the Collision

   Lack of Damage as Evidence of Negligible Force

6. Traffic Tickets and Plaintiff’s Negligence

   Traffic Tickets

   Plaintiff’s Contributory Negligence

7. Admissions, Witnesses, and Statements

   Admissions

   All Witnesses to the Occurrence

   Knowledge of Conversations

   Formal Statements

   Informal Statements and Interviews

   Conversations About the Accident or the Lawsuit

8. Closing

   Photographs and Diagrams

   Closing Questions

Updated annually.  ISBN 1-58012-114-4. Price: $99.00

K6

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Guerrilla Discovery
Handling Federal Discovery
How to Prepare for, Take, and Use a Deposition

Model Interrogatories
Triple-Threat Discovery Forms

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Updated 08/17/06 
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