Lawyers, Start Your Questions - Part I

Depositions are such a common part of today’s civil litigation landscape that much of how they are conducted has become routine.

That includes the opening “admonishments” to the witness. But every witness and every situation is different. Everything you do in the witness environment, right from the start, should be for a reason, not just because you have done it or heard it before.

Both sides — the questioning lawyer and the witness’s counsel — should think carefully about routines like admonishments: whether and when to do them, and how to prepare for and respond to them.