Episode 31 - Clearing Out the Testimonial Cobwebs at the Start of Your Depositions

What's the best way to prevent evasive witnesses, as you wrap up their depositions, from claiming they didn't understand many of your questions, and/or that they were operating under some impairment, and so their answers shouldn't count? Jim Garrity shares a story about a deposition last week in which an adverse witness did exactly that. She claimed she hadn't understood many of his questions, and wanted him to repeat most of them. Jim tells us it was clear the witness had given many false answers, and was looking for a way out. In this episode, he shares his insights about how to lock the exit doors on this kind of witness at the outset of your depositions, and he provides sample questions to ask witnesses, precisely in order to prevent them from later avoiding the consequences of their testimony.

Thank you for listening. And be sure to check out the book on which this podcast is based: 10,000 Depositions Later: The Premier Litigation Guide for Superior Deposition Practice, on Amazon: https://www.amazon.com/000-Depositions-Later-Litigation-Deposition-ebook/dp/B07XTDNTNP