This is the property of the Daily Journal Corporation and fully protected by copyright. It is made available only to Daily Journal subscribers for personal or collaborative purposes and may not be distributed, reproduced, modified, stored or transferred without written permission. Please click "Reprint" to order presentation-ready copies to distribute to clients or use in commercial marketing materials or for permission to post on a website. and copyright (showing year of publication) at the bottom.
Subscribe to the Daily Journal for access to Daily Appellate Reports, Verdicts, Judicial Profiles and more...

Front Page

Dec. 15, 2001

Certain Deposition Questions Need Scripting

You may have heard the old adage that the less experienced the deposition taker, the more detailed the deposition outline. While this generalization contains a nugget of truth, following it to the point that you script most of your questions is a mistake. Follow this general rule instead: Don't script questions, outline them.

        By Henry L. Hecht
        
        You may have heard the old adage that the less experienced the deposition taker, the more detailed the deposition outline. While this generalization contains a nugget of truth, following it to the point that you script most of your questions is a mistake. Follow this general rule instead: Don't scrip...

To continue reading, please subscribe.

Already a subscriber?

Or access this article for $45
(Purchase provides 7-day access to this article. Printing, posting or downloading is not allowed.)