FREE: How to Prepare for, Take and Use a Deposition eBook – 367 pages / 50+ Forms

This free ebook is made available by James Publishing, please CLICK HERE to download it.

Preparation, procedure before, during and after, examination techniques, objections, defense, depositions at trial, videos and computers, and rule updates.

  • 367 pages
  • Over 50 custom-drafted forms
  • Instantly accessible via a link to download Microsoft Word files
Price: free

Proven Deposition Tactics and Questions

This compact, step-by-step guide covers every aspect of the all-important deposition phase of a case: preparation; procedure before, during and after; examination techniques; objections; defense; depositions at trial; videos and computers; rule updates and much more. Now,  How to Prepare for, Take and Use a Deposition can provide greater assistance with the challenges of your next deposition:

  • Pin down evasive witnesses
  • Deal with the forgetful witness
  • Control disruptive attorneys
  • Block coaching
  • Respond to assertions of attorney-client privilege
  • Prepare problem witnesses for their depositions
  • Object to improper questions
  • Deal with tricky examiners
  • Examine experts
  • Summarize and review depositions
  • Use depositions at trial

This tacticians guide is loaded with proven strategies, illustrative questions, response alternatives, and scenario-specific outlines. The following techniques are just a few examples of the practical advice that How to Prepare for, Take and Use a Depositionhas to offer:

Taking the deposition

  • The art of pinning down a witness’ testimony, including the two most useful words in an examiner’s arsenal. §613
  • How to turn long narrative answers into useful testimony. §614
  • How to handle evasive and argumentative witnesses. §615.1
  • Tactics for dealing with the forgetful witness. §615.2
  • Handling objections, including comments on your questions. §631
  • Dealing with instructions not to answer the question. §§633, 741
  • Controlling disruptive attorneys. §634
  • What to do when attorney-client privilege is asserted. §§636, 761
  • Dealing with coaching. §637
  • Responding to claims of work product privilege. §§638, 762


  • How to block examiners who, by scheduling a deposition for less than the anticipated time, like to review the transcript and then re-examine a witness … in essence deposing the witness twice. §421
  • Considering which areas of the examination may invade privileged knowledge. §423
  • Representing a client who will not follow the rules (§438) or is untrustworthy (§438.2).
  • Hints for helping your witness with leading questions, summary testimony, approximations, assumptions, speculation, and more. §440
  • Dealing with examiners who badger, withhold documents, or provide inaccurate instructions. §440
  • Defending the deposition of an uncooperative witness. §455
  • Four techniques for closing a deposition when your adversary tries to leave it open. §554

Deposing expert witnesses

  • The 8 goals of all expert depositions. §600A
  • “Many attorneys are unaware of the limited scope of privilege, if any, that applies to discussions he has with and documents he gives to his expert witness.” Inquire into all documents and discussions. §622A
  • “Too many attorneys waste time asking numerous questions about the expert’s general background or unrelated activities and not enough questions about the expert’s specific qualifications on the subject matter involved.” How to do it. §631A
  • “The expert’s understanding of the case should be developed from his independent review of the facts, but you will often be surprised to hear that the expert is relying on what the opposing party or his attorney told him.” 13 areas to explore. §633A
  • The best way for plaintiff’s attorneys to disarm opposing experts. §637A
  • Form deposition outlines for experts. §641A

This is a free digital book. It is instantly accessible via a link to download Microsoft Word files.

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