
The following is not meant to be legal advice, and may be outdated research.
Here are more guidelines for the attorney who might need to take depositions. For the witness to show credibility in his/her answers, make sure the witness thinks through the answers so that he/she is not inconsistent at later dates. One strategy might be to ask the most important questions at the end when everyone is tired.

Anything not said, such as actions (example: laughing) should be repeated for the record. Make sure the witness is not guessing when answering (personal knowledge). Make sure the witness looks at the examiner, not his/her attorney.
When the examining attorney finishes with a witness, the opposing attorney may ask the witness questions. There is suppose to be an order as to when people ask questions. Address and clarify any issues with the answers.




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