Deposition Checklists & Strategies

by Evan Schaeffer

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Hundreds of pattern questions for treating physicians, corporate representatives, insurers, lay witnesses, defendants, and others. Annotated with strategic suggestions, pitfalls to avoid, and bonus discovery forms.

  • Full-text, searchable CD
  • 60 custom-drafted forms
  • ISBN: 1-58012-114-4
Price: $99

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:

  • Underlying law. Each chapter begins with a summary of the substantive law at issue.  Also included is an analysis of common defenses.
  • 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.
  • Commentary. Thorny or common issues are annotated with practice-proven alternatives and solutions.
  • Bonus outlines. Thumbnail checklists that contain themes and issues rather than question-and answer dialogue are provided for less-common deponents.
  • Related discovery forms. Complaints, interrogatories, requests for admissions, requests to produce, and more finish each chapter.
  • 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

Deposition Checklists & Strategies
Price: $99
Add to Cart
Free standard shipping for online orders