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Teaching Deposition Skills: What Attorneys at Your Firm Need to Know

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Teaching Deposition Skills: What Attorneys at Your Firm Need to Know

Taking effective depositions is a crucial skill for litigators and trial lawyers, a skill that can be taught and learned. But how should deposition skills be taught? A lot goes into taking effective, powerful depositions and a lot goes into defending depositions. Effective depositions can be reduced to mastering certain skills, including conducting thorough due diligence before a deposition, thinking through and relying on your case theme during the deposition, securing all relevant information the witness has to offer, and directing the witness the provide you the information in the manner that you want it. This course will focus on strategies and exercises for teaching deposition skills that win cases.

Transcript

- [Frank] Hi, my name is Frank Ramos and today we're gonna be talking about Teaching Deposition Skills. If you belong to a firm, especially if you are a firm leader, firm manager or administrator, it is an important skill set to have and teach your young lawyers and your junior partners. And often this skill set sometimes gets outsourced. We send lawyers to programs by our state bars by NITA and by others. And I strongly recommend that you create some sort of program or teaching module to show your young lawyers how to take an effective deposition. It's something that should not be outsourced. And so today we're gonna be talking about how you and your firm can teach your lawyers how to develop their deposition skills. And it doesn't really require much work or much preparation. We're gonna go through some exercises, some basic rules of the road and if you can identify in your firm, one or two lawyers that are mentors who are good educators or teachers, good speakers, those are the ones you'd want to lead these discussions. And what I typically do is I recommend that firms have sort of a lunch and learn where they get together maybe on a weekly basis or a monthly basis, and they go through a number of these exercises. And so taking or teaching deposition skills. Anyone who has taken their share of depositions can teach what they do to others. Each of us can sit down, analyze our process and share our wisdom, approach and skills. The more depositions we take, the more we learn and the better we get and more insightful knowledge we can pass on to others. So, first identify at your firm, you know, who are the ones who have taken the most depositions, who have been in the trenches the longest and have deposed all types of witnesses. Whether they be fact or experts, lay or whatever they may be in different types of cases and different types of matters. And those individuals have probably had developed a certain way of approaching depositions. They have their own rules, the road, they may have checklists, they may have other things and these are probably the best persons to provide that type of skillset. And so what we did at our firm a while back when we were teaching our associates deposition skills, and we'd go and we'd do other types of luncheon meetings where we sit down with them and kind of give them refreshers is that we kind of first explain what a deposition is. And where we start and where we go. And we start with the basics. And I think it's important for when teaching or training guard lawyers on deposition skills, having them understand why we take depositions. You know, depositions are time consuming, they're expensive, they take a lot of effort and it's important to one, understand why we're doing it. And when I was younger and I started out as my career, I just assume, oh we depose everybody. Anybody who may have any information, you just go out. You asked a bunch of questions, you find out what they may know. And that's the process. And that's really just sort of stretches the surface. Knowing who to depose, what order to depose them in, what questions to ask, what documents to show them. These are all part and parcel of the process of developing effective deposition skills. So an effective depositions begins well before the first question is asked. And one of the necessary prerequisites is securing the relevant documents. The attorney deposing the witness responsible for securing all documents needed. And one of the first things to teach your attorneys is to understand what documents they need to have in hand to either learn more about the witness or the facts of the case or to use as potential exhibits to cross-examine a witness with. And so document gathering is so crucial. It seems kind of rote, it doesn't seem like something particularly important or necessary, but understanding what documents to secure and what to do with them is really important. And so one of the first things I would sit down with your team is to understand the process of gathering documents, both formally and informally. Both in terms of just asking for securing documents from clients or securing them through subpoenas or through freedom of information requests. Or in Florida we have Sunshine Act where we send out letters pursuant to statute to get documents from governmental agencies and so forth and gather them all. And as you get more records, you'll probably see other documents reference other, perhaps providers if it's a personal injury case or other companies, if it's a commercial matter. And then there are other entities to then follow up and procure those records as well. And once you have all those records, you know it's important to have them before the deposition. And the more you know about a witness, what she knows, her role in the case and what she's likely to say, the more affect the deposition. Thorough due diligence improves the effectiveness of any deposition. And so I try to do a thorough and complete background search in the witness. Either I do it or someone else in my office does, often our paralegal, and we determine whether they've been involved in any prior litigation. If so, we pull the docket sheets and see if they've given prior testimony or have sworn to interrogatories in another matter. I look through any relevant court documents I'd go through if they have a personal website, go through social media, procure any public information available there. See if they have a online resume such on through LinkedIn, see what they're posting on LinkedIn and other platforms, see if they've written anything. You know, I basically try to find any and all information about that witness. And at the time I'm gathering the information, I look at it almost as sort of a funnel where I get everything there is available. And at the time I'm gathering, I'm not being choosy or picky as to what I get or what I choose. I look at it all. And I look at it through the prism of the case and then decide what is relevant and useful for this deposition? What isn't? And sometimes, let's say I may gather 50 plus documents on a given witness through you know, their prior testimonial history. Cases they've been involved with. Testimony they've given other matters. And from all that information including social media and so forth, I may only have eight or 10 documents or even fewer that I'm gonna use in this given deposition. But they may be very relevant or important because they establish the foundation for a given admission or statement, I'm hoping to procure from a given witness. So the first thing in any deposition before you sit down and you write your outline is to find out everything you can about a witness. Secure all relevant documents, review them. And often I will have myself or someone else create a timeline where I take all the relevant documents, it may be correspondence or emails or text messages, maybe photos, it may be contracts, it may be surveillance video, it may be some other form of video and we create a timeline and it shows all the documents that are relevant in chronological order generally with some sort of summary summarizing or indicating their relevance. And that becames a growing organic document which is sort of the backbone of the case, which will be augmented and changed and revised during the course of the matter. But it is the document that I will constantly refer back to for any deposition I take or any motion I prepare, any discovery I propound it is sort of the through line that allows me to better appreciate the case. And there's various software by the way out there. There's CaseMap and other software that you can use that helps you do these sorts of things. And you know, I'm not gonna recommend one platform or another, although I did mention CaseMap, but there are lots of them out there. Some folks just like using your Excel spreadsheets, some folks like using word charts and some folks like doing something a little bit more detailed and thoughtful. That's entirely up to you as to how you do it. You have to find a mean and a process that works best for you. Excel spreadsheets is typically something we still use. Whereas we create an electronic binder that has as the first document, the outline or the timeline, however you wanna refer to it. And then it is linked to the various documents referenced they're in. And these days and most of these depositions are being done by Zoom and that still remains the case here in Florida, you know, a number of years after almost three years I guess now since the beginning of the pandemic. And so by having an electronic file where you have all the relevant documents in chronological order, it's easy to pull that up and share your screen on given documents and question witnesses and deponents that way. So that's something I enjoy doing. And so talking about developing themes. When you have everything together, you start thinking about the theme of your case. And the objective in any case is to win and to win, you need to develop a theme for that case. A theme runs an invisible line through your case. It's sort of the through line of your matter. And the theme is developed through case investigation, written discovery, interviews and depositions. And so teaching deposition skills requires teaching how to spot, grow and develop themes. Themes keep us and the finder focus on why we win. Define your theme, embrace it and use it. And so you can't teach deposition skills without teaching how to create and pursue themes for your case. And so in any training that you provide, you have to teach your attorneys to think about themes. And once you first get a case, whether you're the plaintiff for the defense, whether you're prostituting a matter or defending it, you have to think through what is the central theme or themes of this case and what is the case theory? And those are sort of the foundations for the rest of your case. And you may start with a theme. You may end up abandoning it, you may evolve it, you may change it. But no matter where you are at the very beginning of your case, you have to think through what central theme you want upon which you're going to build your case around. And what I teach folks is I generally suggest that they start thinking of themes and sort of cliches or catchphrases or sort of, you know, even things that it may be a lyric to a song or a line from a movie. It may be an idiom of some sort. One of the books I wrote, let me just kind of take a step back about some books I've written that may you may find helpful, they're free. If you go to my website, miamimentor.com or if you visit my profile on LinkedIn under Frank Ramos, it should pop up under publications, you'll find these publications and they're free. One is the Associate's Handbook, which goes into some detail on how to develop and use themes and use thematic elements and recommend that book to you. It was published by the Defense Research Institute's a free ebook and get a PDF of it on my website or on my personal profile on LinkedIn. And by the way, since we're talking about teaching depositions skills, one of the books I wrote is, "How to Do Just that." And again, you can find that book for free on both my personal website miamimentor.com or on my profile under LinkedIn and it'll have various exercises, go into greater detail than we are going into today. And how to teach depositions skills. So we talked about finding all the relevant documents and that's so very important because if you think of any case as sort of a puzzle and trying to really understand the strengths and weaknesses of your case, you're trying to find as many puzzle pieces as you can. And I think younger lawyers think we're gonna find all the puzzle pieces. Having been doing this for 25 plus years, I realize that's almost an impossibility. There's always gonna be a witness or a document or a bit of information that is beyond your grasp for one reason or another and you're never gonna have the complete story, but you're trying to get as close to the complete story as you can. If you can get maybe 95% of the puzzle built together, I think that's great. And the more of the puzzle you put together, if you're being objective about your case and your clients are being objective, you can have an honest and earnest evaluation of the strengths and weaknesses and the value of your case. And by getting as much of it together, so you're gathering all the relevant documents and information and talking to the relevant witnesses and consent, you can't speak to somebody you know deposing them. You'll have a much stronger sense of what this case is about and you'll have the information you need to develop the themes and the theory. The theme is by the way is sort of like the catchphrase or the hook for your case theories for the legal basis for your case. In a case where let's say you're taking auto accident case, defending the claim and you believe that the plaintiff was actually at fault. And so it's a comparative fault case. You know, the theory of the case is comparative fault and the theme may be something about, you know, the plaintiff having to take responsibility or being responsible or whatever it might be in efficiency, how they kind of work hand in love. So developing goals. Once you have the documents and the theme, you have to sit down and figure out what your goals are. You know what needs the goal when taking a deposition? What information are you trying to procure? What admissions are you trying and secure? What themes do you want to develop? Depositions are more than just asking questions and soliciting answers. They are about advancing your overall case goals. Learning to develop goals for depositions ensures that the questions one asks best serve the case and the client. And so before you sit down and you're write an outline, and I think most people think, "Oh I got to sit down and write an outline." It's one of the first things you should do. I would recommend when you teach your folks how to take deposition skills, that's one of the last things they do. When they sit down and they write the outline, it should come very naturally 'cause they, you know, they've looked at all the documents, they've developed a theme and a theory. They set out goals for themselves in terms of the information they want to procure and the admissions they wanna secure and what themes they wanna develop. And at that point coming up with an outline becomes a lot easier. Remember the depositions again are expensive. You generally will get one shot at a witness and you're trying to create testimony that will help you at mediation, at trial. I think early on in my career I appreciated that it wasn't about learning what the witness had to say 'cause if I did my due diligence I generally knew more or less what the witness was gonna say. Not always but often it was more about getting the witness to say what I wanted him or her to say what I wanted them to say and I and how to get them to say it. Getting back to the catchphrase of the theme of your case. I think there's no bigger home run than getting a witness to use those words and having them come out of their mouth. Whereas you know, you have a given theme or catchphrase you're trying to use and you get the witness to parrot that catchphrase and not only once but maybe several times. And you do that consistently over a series of depositions so that when you present your case to the jury, now I understand that 98% of cases settled but every deposition has to be taken with trial in mind. And if not, then you're really kind of wasting your time and your energy. And you're not really showing the other side that you know how to try cases. I can quickly know based on how somebody takes the deposition, whether the attorney is a litigator or a trial lawyer. And distinction in my mind is litigator gets a case ready for mediation and a trial lawyer gets a case ready for trial. One party is trying to settle the case, the other party is trying to trial the case. And the paradox is that the more time you spend trying to get case ready for trial, the more likely you're gonna settle it on terms that are favorable to you because you've positioned yourself as best as you can to trial the case. And most lawyers don't do that unfortunately. Most lawyers are just thinking of trying to settle the case, trying to mediate the case or not thinking ahead about what witnesses to call? What they're gonna testify to at trial? What documents or evidence they need to get into trial? And how they're gonna do that and leave the foundation for those documents. They are really just trying to get the other side to either take their offer or take their demand or whatever it might be and try to resolve it and they generally find themselves in a weaker position. So by teaching your folks on how to take each case as if it's going to go to trial, you will be much better positioned to actually settle the case and you'll be, you'll be sort of in command. You'll be the person being more proactive. You'll be the person situating the case in such a manner that when you go to mediation, you have a settlement conference, you try to resolve it, you're likely to get a number well within the range you've conceived is a proper valuation in your case. And so that's really important, you know, developing goals and so forth. And outline preparation. Most lawyers prepare deposition outlines. Deposition outlines, help ask the right questions in the right order and use the right exhibits in the right order. Understanding the role of deposition outlines and how to prepare them, ensures a more productive, effective deposition. So now we're getting to the point where we're talking about outline preparation, where I think a lot of attorneys think that's the first thing you do, you're prepared to outline. And it's actually one of the latter things that you do. And you know, you get the documents, you come up with a theme and you come up with goals. And what I like to do when it comes to goals is before I prepare the outline I'll create a Word document and the first thing I'll write down on the Word document is what my theme is. I may have multiple themes, that's really the case and I'm trying to test different themes, trying to see which ones resonate, which one's working, which ones don't. So maybe early in the case you may have three or four themes you're playing around with and trying to figure out which one really is the best one. At the end of the day, you need a theme, you don't need multiple themes, but early on in the case it's okay to have more than one theme. And same thing with theory. You may have more than one theory of the case 'cause you don't have all the facts or all the information. Even under your best circumstances you may not have everything. And so you're trying to figure out which theory plays out the best. And so on that Word document or Word processing document, I have my theme or themes, my theory or theories. And then I write now what are the admissions I think I can get from this witness? What do I want this witness to say that's gonna help my case or hurt the other case? What statements can the witness testify to that will bolster my theme, that will support my theory and that will undermine the other side's theme and theory? And by the way, early on, not only are you trying to identify your theme or theory in your case, you're trying to figure out as best as you can what the other side's theme or theory is. And sometimes they right off the bat they're developing it and you can see again the difference between a good trial lawyer and a bad one is somebody who clearly has early on developed a theme and a theory and they're trying to get witnesses to support that them or theory. And they're testing it out on different witnesses, they're trying to get a witness to say certain things in a certain way and those are the sort of lawyers that are gonna be the ones who are gonna put their cases in the best position. And whenever I report back to a client about our case and whether we have a good case or a strong case, invariably a couple of the things that I do is that I provide some sort of valuation about our judge and you know, determine whether he or she is somebody who will find favorably for us. And you know, I'll go on West Law Edge or, and I'm sure there other platforms, Lexus probably has a similar one where you find out more about your judge, find out the types of cases they've handled and how they've ruled on this positive motions, how long it takes them to rule on them and how often they actually find in favor of a dispositive motion. And not to digress too much had a judge where we had a matter and this judge don't even wanna provide the gender 'cause I'm in day town yet I don't wanna reveal who this might be. But this judge had probably 500 motions for summary judgment and wholly ruled on a dozen of them and had denied all of them. And so this judge basically would repeatedly cancel hearings and motions for summary judgment hoping the cases will ultimately settle or be tried, I suppose. And everybody who appeared in front of this judge knew that they weren't gonna get a summary judgment that no matter how strong of a case you had, no matter how clear the facts were, you weren't there to get summary judgment. And so you're either gonna settle it in mediation or you're gonna try the case and something good to know. And I also want to know, getting back to my earlier point about opposing counsel, I want to know if this attorney is preparing the case as if it's going to go to trial or if it's gonna go to mediation. 'Cause if it's go mediation, they're more likely to take a number that is at or below a real evaluation of the case in order to avoid trial. This may they don't try cases they don't know how to try cases, they're not comfortable trying cases, they haven't had much success in trying cases and quite frankly it, it becomes clear on the questions they're asking and how they're conducting themselves in deposition that they don't know how to try a case 'cause they're not using the deposition as a jumping off point for trial testimony. You know there's that thing about trial, you don't ask a question you don't know the answer to. The whole point of deposition is to test out every question you intend to ask at trial no matter how small or minute. So you know what the answer is. And when I try a case and I'm cross-examining an adverse witness for the opposing party, the opposing parties expert. I have the questions on my left hand side. On the right hand side I have either the document or the testimony that supports the answer I want. And I find that people who aren't particularly effective at taking depositions often have to ask questions they don't know the answer to or have to limit their questioning significantly 'cause they never tested out the lines of questioning in deposition. You know, they just asked a lot of questions about what happened next? What do you know, what else do you know? So there's very open-ended questions that don't lend themselves to procuring the information, the knowledge you need to conduct an effective cross-examination. And so understanding what you're trying to do will help you be able to write a more effective cross-examination outline. And so the flow of questions and what to ask. Every deposition has its flow. Learning how to order topics and questions will help you secure the answers you're seeking. A deposition is part interview, part reconnaissance and part interrogation. Every deposition calls for its own questions to ask. And developing a process to determine what questions to ask is a skill every litigator should develop. And I think it's important to understand, you know, obviously at the superficial level, yet, you're trying to find out what the witness knows. And at a more deeper level you're trying to really dig deep as to that level of knowledge. You're not asking over or general questions, you're really trying to figure out the full scope of that witness's knowledge. And that takes some skill to really dig deep and find out everything that witness may know about your case. But more importantly, you're conducting an interrogation. This is not a friendly interview. This is not a casual conversation you're having with someone. You are getting into the weeds and you're getting that witness to say what you want them to say. You are the puppet master. The witness is you're marionette and you're trying to get the witness to say your words out of their own mouth. And again, depending on the deposition, if it's an adverse witness or a hostile witness, you can lead. And so a lot of your questions will be leading. If it's not, then there's still other ways of trying to get the witness to say what you want them to say. So how to ask questions, you know, what tone should you use? What's your cadence? How should you behave? What should be your approach? Your attitude? How fast should you ask the questions? How loud should you ask them? What rapport are you trying to develop? Remember you're trying to get the witness to tell you what you want, what helps your case and what bolsters your theme. How you ask questions goes long way in determining whether you secure the answers you want. And so depending on the witness, you may be very casual, you may be more formal, you may be more friendly, you may be a bit more aggressive. I don't like really like using the word antagonistic, but I suppose it fits. You're gonna have to size up the witness. That's why the background search you use with witnesses is so important. Really learning more about the witness, especially if they've given a prior deposition, read it. If they've signed interrogatories, read those. If they've ever provided any sort of video, maybe they're on YouTube, they've provided video and other platforms. See how they speak, see how they communicate. See what they focus on because you need to know all this to better use them to your advantage. You are an interrogator, you have a limited amount of time and you are trying to get information that's gonna help your case. And if it's a opposing party or an opposing expert, the opposing attorney has prepared that witness to stymie your efforts. Their approach, if they've done their job, this witness is not gonna be especially cooperative. This witness was not gonna be helpful. This witness is just not going to parrot what you're trying to say and you're really gonna have to be thoughtful and how to secure the admissions you want. And no matter how well a witness is trained. No matter how well they are prepared, if you are persistent, consistent and have a game plan, you will procure some admissions. You may not procure all of them, you may not get all the answers you want, but if you continue drilling down and you have a methodology and a method to your madness, then you will likely get a number of very valuable and have full responses. So deposition exercises, using exhibits. There are a number of times where you're gonna have to use photos for depositions and often that's also used at trial. So try to teach your folks on how to use photos. Often you'll need to show a witness a photo and have her identify and describe it. The photo needs to be properly identified for the record. And the photo and what it depicts properly described for the record. You know, becoming comfortable with using photos and depositions is an important skill to develop. So what I recommend during these lunch and learns is to take photos and diagrams and other documents you've used or had admitted in deposition red trial. Explain to your attorneys how you did it or how someone else in your office did it. And then work through the exercise with them. Have them introduce a certain photo. And same thing goes with diagrams. You may use a diagram, a diagram of an accident scene attached to a police report, a diagram of a floor plan, a diagram of a product. The questions a witness. You'll need to know how to identify the diagram and it's contents and how to use it with a witness. Diagrams can include useful information and exclude useless information often found in photos. They draw your attention to the issue at hand and keep the deponent focused on what matters. So when I talk about diagrams, an obvious one is if you're doing an accident, auto accident and you have the police diagram, which I often use and sometimes you can create your own diagram. If you're having a floor plan, you may use a floor plan and have additional information. It's really important to know where somebody was or where people were situated in relationship to each other. You may have a photo of the area, you may turn into a diagram. You may have some sort of information where you, you know, make sure everybody have the witness plot where everybody is. And again, use something you've done in a prior deposition or create one and walk through and teach your young lawyers how to use it. You know, not only what diagram to choose and what to include and not to include in the diagram but how to reference it in deposition so it's clear on the record what is being used and what is being referenced. But often what happens is you'll have two witnesses, well I just one witness and one interrogator asking each other or responding to one another are questions about a diagram. And the two of them may like, it may seem as if you know you're asking the witness questions, it seems like it's coming across clearly and making sense, but when you get the transcript a few weeks later. You're really not sure what you're talking about because you're not properly identifying the diagram or you're not properly identifying where a witness is marking a diagram. And by the way, when you're gonna have a deposition that is heavy in exhibits, especially in visual ones, I strongly recommend that you conduct a video deposition so that in conjunction with a transcript you have a video. And so it's easier for the jury to see the witness reference the diagram. Especially if you don't have a witness who's not gonna appear at trial or if you need to cross-examine the witness with a document and they find some way to try to end run it because the transcript isn't that clear. You have the video to show what they're referencing and what they're looking at. Emails. Many cases emails play an important role, they contain an admission a fact or provide notice that's central to the matter. Emails can be critical in putting down a witness with his own words or showing that he was a recipient of an email, thereby placing him on notice of the email's contents. An email, you know, show who it's from? Who it's to? Who's copied? Who's blind copied? It may have attachments, it may reference other emails. It may create a chain or may be really significantly important to terminology you're preparing. So teaching people how to spot emails. What's important about an email? What to ask about an email. It's a more than just the body of the email. You know, what was the ray line? Who's copied? Who else may have said something? When it was sent? When it was it received? When it was it responded to? Are we almost like a regular conversation or is it something less than that? You know, what's going on with the email showing your people how to do that. Using contracts. You know, learning to use contracts as a deposition is a two-step process. First you have to become acquainted with the different types of contracts, different parts of the contract. The definitions and contracts and the meaning of common clauses and contracts. If you're gonna do commercial litigation and you have to understand what you're looking for and you're trying to understand what's being said in the contract. And then you have to learn how to question a witness about a contract. You lay a foundation with a witness about their knowledge of an exposure to a contract, their role in drafting or applying it, their understanding of key terms and the basis of their understanding and how to use the language or contract to pin a witness down. And you have to take your time when questioning a witness about a contract, especially if it's integral to your case. There may be a specific clause and how it's being interpreted or construed or who drafted it or what was said to draft it. That is integral to your case. And you never just jump into that clause, that's a mistake. What you do is that you have a more general discussion about the contract. And again, we're approaching it from sort of a funnel system where you are asking broad-based questions about the contract, about the deponent's role in the contract, about their understanding of the contract. Any emails or other communications regarding the contract. You do go through some of the more general terms, clauses, definitions. So the witness is pinned down. You're consistently trying to pin down the witness on more general things and on general definitions and general concepts so that when you dive deep into a specific clause, you've closed all the doors and it's easier to lead the witness as to a specific clause when you address the more general things so that the witness can't escape and run through say, "Well, that's not what definition meant." Or, "That's not what we said." Or by the way there was some other email you go from general to specific, you close all the doors and all the windows. You create this funnel with a witness is going to invariably or inevitably hopefully answer questions that you want 'cause there's no estate latches involved. Using medical records. In any personal injury, these are important. And so you use medical records when questioning treating physicians, experts of plaintiff and lay witnesses. In order to depose a physician for example, you really have to have their complete file an understanding of relevant medical terms and concepts and how a given record plays into your overall case theme and theory. You should be able to explain the different parts of medical file, the purpose of each and how do you use each in deposition. Whenever dealing with medical provider and medical expert, you need to understand the medicine. Obviously you're never gonna understand it as well as a physician. You didn't go to medical school, you didn't intern or have a residency anywhere. So you are to some degree at disadvantage. And how do you make up for that? One, you have to have your own expert. You have to have your own expert explain to you the relevance of specific documents or information or findings or whatever it might be. You have to be familiar with the nomenclature, know how to pronounce the nomenclature properly and have a foundational understanding of the medical issues so that the doctor and deposition can't run circles around you. And you have to lay the foundation and you have to be able to speak about this in the layman's terms. Sometimes you're dealing with very esoteric, very detailed, very difficult medical concepts and issues. And ultimately you're gonna be explaining this to a lay witness or lay jury I should say. And the jury who aren't comprised of doctors or nurse practitioners or nurses and probably do not have any medical background, they have to understand your case and the medical issues revolve. And so taking time with your team and having them understand the medical terms and chronology, having them learn how to investigate that specific medical issue or treatment. You know a common thing is in auto accidents or herniated discs. Understanding the anatomy and the physiology of a trauma or an impact and how that may affect one's invertible discs and the surgeries resulting from it in the long-term prognosis and the long-term treatment. This is all part and parcel of being able to conduct an effective deposition. Just going in and not really understanding the medicine or understanding how a doctor can turn the medicine and use it against you is really a bad situation to find yourself in. So spending some time to teaching your people how to do that is important. You know, using videos. Sometimes you'll question a deponent about a video and a number of logistics are involved, you know, where and how do you play the video? Specific equipment will be needed to play the video. How do you capture the witness answering questions about the video? Position the witness of both the witness and the video can be seen simultaneously. You know, how do you maintain an element of surprise about the questions you're asking about the video? The recording of the deposition must reflect the witness, the video she's watching and her interacting and responding to the video. And these days it's really hard to surprise a witness, you know, through written discovery. It's hard not to show what information you have to the other side. And so there're not that many secrets anymore. You may have a surveillance video when you're showing a plaintiff. You know, surveillance may be at the time of the accident where it shows how the accident happened or may be subsequent surveillance of the plaintiff. There may be a video of an accident at a stop sign or traffic signal or body cam of a police officer. You know, if you're representing or defending an officer, that's the force case. The body cam videos are really important. If you're handling negligent security matter, you may have surveillance video of the surrounding area or inside the commercial place. And so understanding the video, making sure that it's the full video that you're looking at, that it hasn't been edited, that it's not been corrupted. Understanding what's involved, making sure if there's any sound you have that and really studying it. And ultimately if you can study it with your expert or with another witness or with your client, that's very crucial. And so explaining all this to your team is very important. And having a witness mark exhibits. You know, knowing how to walk a witness through marking an exhibit and making records important in cases where exact locations or distances are relevant. You know, committee a witness to the exact location on a diagram, having your marked that area can serve you well at mediation summary judgment or a trial. Now it depends on the jurisdiction. Some jurisdictions may not allow you to have a witness marked in exhibit. Florida, we can, I think there's a case law, there's cases that suggests it's certainly permissible and I guess it comes up or it's debatable sometimes. And sometimes you know, an attorney may intervene, they may suggest they can't do it. If you know you're gonna have or you want to have a witness marked in exhibit, you know, put their initials somewhere or show where they were standing or situated. Look up the relevant case law in your jurisdiction know whether or not it's permissible and have that case ready to go so that the opposing party objects or instructs the witness not to answer. You have the relevant case law or secondary source to show the other party and other attorney that in fact you can do just that. And then using technology. Learning what technology's available and how best to use it can give an attorney a distinct advantage before a judge and a jury. Having an open discussion about how best to use technology improves a firm's use of technology. Not only depositions but a hearings and trials. And so if you're going to have a virtual deposition, you know, know how to screen share, know how to pull up a document, know how to highlight or call out a part of the document. Know how to find the proper portion of the video and play that video. Whatever it is, become acquainted with technology. There are platforms, there are apps, there are different items or things you can use, both hardware and software where you know, you're showing diagrams or images or documents or you're showing exhibits or emails, whatever it might be, text messages. And you're doing it in such a way that's visually captivating. It's understand that ultimately what we're doing here is when we're capturing this information and asking these questions. We're doing it in such a way that will resonate with the jury. And so whatever information we're calling out and however we're doing it is a informative, interactive, eye-catching manner. So gathering information. That's obviously an important part of taking depositions. One of the purposes of a depositions is to learn what a deponent knows about your case. Learning to follow up with a deponent, explore topics, press a witness and seek details, ensures you leave a deposition knowing what a witness knows and avoid being surprised by her trial. Keep asking questions, explore the full running or scope of their knowledge, understanding and memory of witnesses. Learn to listen to deponent what they say and what they don't. Study their body language and push them to reveal everything they know. I am surprised how often when I read others' transcripts where it's clear that the witness had more information to divulge and the cross examiner didn't pursue it. They got distracted, they didn't think about it, they moved on to another topic. And the witness, it was fertile ground to explore information. And sometimes you get information you don't like, you don't want, but it is what it is. And I'd rather know in a deposition than at trial. I'd rather know full, especially if it's a witness I can't talk to. You know, obviously if it's an opposing party, if it's an expert witness, if it's bad, it's bad, I need to know it. You know, some people have this approach depositions that they don't want to have any bad answers. They don't ask any questions that may lead to bad answers, but that's not really an effective way of taking a deposition. You got to take the good with the bad. You have to know what the witness is going to say at trial. Whether they help or hurt you, how they come across. And sometimes a witness may have something bad for you to say, but they're not particularly effective in communicating it or they can't really express themselves very well. And so sometimes a bad fact isn't quite as bad and you would never know that unless you asked those questions. So laying a foundation and delving deep. You may need to lay the foundation for a witness's knowledge or expertise or lay the foundation for a budget you're asking about. You know, sometimes it is okay, okay to jump right into the topic, but more often than not you need to lay a predicate. Getting to the bottom of the topic or issues takes time, patience, effort, and many, many questions. Covering the waterfront, developing deep and exhausting all the questions that can be asked requires you to know your case. The documents, the facts and the witness. And so again, there are the big admissions you want. The sort of the answers that are really you can use in a summary judgment or mediation or a trial. But it is really hard to just jump into that 'cause you're never gonna get that question. You need to lay the foundation, what a witness knows or doesn't know, what their expertise are? What they're relying on? And trying to figure out exactly what the basis of all that is before you really get into nitty gritty. And sometimes you have to ask a lot of questions. You really have to delve into a lot of issues and you really have to kind of cover the waterfront to figure out what the witness may know. And so it's turning over every stone. You know, part of our job is turning over every stone, evaluating every avenue and considering every angle. It takes imagination to think through all the angles and perspectives and explore them with a witness. Exploring the full breadth of the witness's knowledge and understanding can help avoid surprises during trial. I don't want to learn for the first time some information that the witness has that I didn't ask the deposition it. So cross examination is one of the biggest skill sets you need to know. Asking leading questions. The first rule of cross-examination is to ask leading questions. Testify for the witness. It takes practice to turn every open-ended question into a leading question, but with practice can be done and done effectively. And so first of all, you have to ask yourself, can I lead this witness? Is an opposing party is an opposing expert? Is it a hostile witness? If it is, lead the witness. Asking yes and no questions. As a cross examiner, you're testifying and the witness is agreeing with you. Ideally, you're getting the witness to say yes repeatedly. When appropriate, you're getting the witness to say no. Start with one's objectives with a witness and think through all of the yes or no questions to get there. And so again, I'm trying to get the witness to parrot what I wanna say. I'm asking a leading question, a question which responds yes or no. I'm asking one fact per question. The less information you ask a witness. The more basic your questions, the more likely you're secure a favorable response. Learning how to ask one fact per question, it stands a favorable response. And cross-examination prevents witnesses from taking issue with your questions and providing unfavorable responses. I'm asking basic questions. Lawyers can use complex words, phrases, and questions. It's important to keep them basic so the jury can understand them. Simple questions, prompt simple answers. Again, you're thinking about not only the question, answer for the specific witness so that they understand you and they can't, you know, vain confusion or misunderstanding. If it's a simple question and they don't seem to understand it, it's clearly that they're trying to avoid answering it. And that's gonna come across to the jury. And I ask short questions. Asking short questions, creates a quick cadence back and forth between the interrogator and the witness. The fewer words in a question, the better. Long questions can be confusing, difficult to follow and invite long answers. Try keeping your questions to 10 words or less and then try to do it in five. Think about, taking your questions and see how you can divide them up. You know, your questions shouldn't have a compound clauses. They shouldn't be, especially long. They should just be as few words as possible. Each question leading to the next question. And you get into the habit of doing that. You find that your questioning is crisper, it's tighter. You're more likely to get favorable responses because you're not giving the witness a whole lot of space to maneuver. You know, the questions are short, they're to the point, they're direct, they use common words and phraseology and they really should only require one answer. And it's the one you're looking for. Expressing your theme. Your theme holds your case together. Learning how to weave your theme into questioning to have witnesses bolster your theme is an important skill to develop. Learn how to highlight your theme and get witnesses to agree with and support it. And again, if you can, if your theme can be reduced to like a cliche or catchphrase, if you can get that witness to actually use it and use it repeatedly through their testimony, that's very effective. Security admissions. One of the most important objectives at a deposition is security admissions to win at summary judgment, mediation or trial. Any witnesses agree with you on central questions can result in resounding win. And so think about what you want this witness to say that will help your case and undermine the opponent's case. What is an admission or a statement that would be perfect to put in a summary judgment to reveal to media mediation to share with a jury at trial? Those are the admissions. Causing witnesses to lose credibility. Jurors relate to witnesses on two levels. Likability and credibility. Does a jury like the witness and do they trust the witness? Undermining a witness's credibility can sideline them and make them impotent in the eyes of the jury. And what I mean by that is sometimes if you get a jury to argue with you, you get a jury not to agree with some obvious statements you are making. If you know they insist that the sun is blue or that the sun rises in the west. One level you're thinking about, I didn't get him or her to agree with what I said, but they're disagreeing with such an obvious statement that the jury just doesn't believe them anymore. Sharing what the witness doesn't know. A way to undermine or limit the witnesses by showing what the witness doesn't know. Perhaps he didn't hear, see something. Perhaps he's not aware of a statement or document. Revealing a witness's ignorance can undermine his testimony. Especially if you have an eyewitness and you know the eyewitness may not have had their glasses on or may have been too far away or was doing something distracting like they were on their phone. That all goes to undermine what the witness saw or heard. Funneling. An effective cross-examination technique is going from general to specific, broad to narrow from large to small. Funneling guides the witness to the end of a long narrow hallway with no exit and provides a pathway to an inescapable result that benefits the questioner. And commit and confront a witness. Knowing how to impeach a witness with their own words can be devastating and deliver a death blow to credibility. Learning when and how to impeach a witness can create a memorable moment that can define a case. So I think that's a skillset that's often overlooked and probably not well taught. And I know most of us at least, I hope most of us learned how to impeach a witness in law school if we took some sort of trial skills program. But if we didn't, we may not have. Maybe we learned how to do it in our evidence class. Teaching your attorneys one, when to impeach a witness in terms of, you know, is this fact important enough to impeach them over? Two, making sure that it's impeachable. Making sure that the statement actually contradicts their prior testimony 'cause sometimes it really doesn't. Sometimes more or less the same. You look foolish by impeaching a witness with a statement which is similar to what they just testified to. And then three, the pragmatic of it. The actual step-by-step guide and how to do it, that's important. The jerk witness. Sometimes you'll have an adverse witness who makes things difficult. It takes practice and patience to extract information in admissions from a jerk witness. And again, when you're trying to size up a witness, are they cooperative? Are they belligerent, are they helpful? Are they trying to hide something? As much or more that you can learn about them beforehand. That's really important and relevant because that will help you know how to approach the witness on cross-examination. So cross-examination trial. There's a difference between cross-examining a witness at deposition and cross-examining a witness at trial. At trial you have an audience. You must learn to be comfortable with a witness in front of an audience. Work on your tone, inflections, cadence and body language. There's things I'll do in depositions I would never do at trial. I may speak a lot faster, I may be a bit more aggressive. I may certainly ask questions I wouldn't ask at trial. Since I'm trying to figure out what the witness knows and what admissions I can secure. So always keep those distinctions in mind. Let's talk about opposing counsel. Handling speaking objections and interruptions. Speaking objections are considered witness coaching and are prohibiting most jurisdictions. Even so many attorneys use speaking objections. Understand the rules applicable to your jurisdiction on speaking objections and how to confront the attorney using them. Some attorneys may interrupt your questions, give speeches or make statements to coach their witness. Be prepared to deal with these scenarios when they arise. And in Florida, for example, we have a handbook that we use both the discovery handbook and a professional handbook. And each of them addresses speaking objections and how they're prohibitive and can't use them. And if I have an opposing counsel, I think based on his reputation or her reputation, that they are the type to use speaking objections, I will have that document prepared for me and ready for me. So it's ready to share or use to the other side. You know, if I have an opposing party and they're using speaking objections, I'll say, "You can't do that." And they'll say, "Oh, you can't tell me not to do that." And I'll say, "No, look at this document. You know, references are rules of professional conduct explicitly says that, 'The only words you can say are objection to form.' You're going well beyond that." And you know, there are times it's happened rarely, I think once or twice in my career where I've had to call a judge and get them involved. So I always keep the judge's number handy if that's necessary. Defending depositions. Preparing a client. The client's deposition is crucial and you must spend as much time and energy as possible to make sure the client performs optimally at deposition. Deposition preparations may extend over several days to ensure the client knows what to expect. Consider various approaches to preparation to decide which is the best approach for a client in any given case. Preparing materials for the client. Typically when prepared is a binder or email with attachments to the client with unnecessary documents needed to prepare. Deciding what to send the client is both an art and a science. You wanna send everything she needs, but don't want to bury them in paperwork and overwhelm them. And the rules, you know, you need to like know what the rules of the deposition are. You know, typical rules tell the truth. Answer only questions asked. Wait two full seconds before answering your question. Interrogate the interrogator. It's important to think through what your rules are and how to share them with a client. What I do is I think through what all the rules are and I'll tell them the client and I'll go through and do a mock deposition with the client. The best way to prepare a client is through a mock deposition. I ask you the tough questions, have her answer them, and help her work on her answers. Both, you know, substantively and stylistically. I wanna make sure that the answers are coming across in a way that sound right and are appropriate. And ideally, you want your client to say that her mock deposition was tougher and then prepare her for the real thing. And that's really, it's so important when conducting mock depositions and trying to get people ready for that. And appropriate objections. You know, when defending deposition, an attorney is limited in how to object to questions. Typically objections are limited to the form of the question unless privilege is at issue. And you know, lawyers must learn what deposition, objections are appropriate. And so that's important to keep in mind. You know, handling overbearing questionnaires and bullies. Sometimes the attorney when questioning a deponent will be overbearing and sometimes opposing counsel will simply be a bully. Having a planner approach for this scenarios necessary. Understanding the line between thorough and overbearing and centering, observing the record reflect the billing. And sometimes you have to terminate a deposition. It is rare, but sometimes an attorney's behavior so over the top, that one must terminate a deposition you'll have to justify for the court. And you may face sanctions if you're wrong for doing so, so keep that in mind. And determining the line for termination and recognizing how to lay a foundation to show you're correct for terminating. And so these are generally the skillsets. And what I recommend that you do with your team is that you come up with a schedule of lunch and learns, and you can probably do within, you know, five to 10 is probably appropriate considering the amount of skillsets. You can do one on, you know, preparing, gathering documents and creating chronology. You can do one on preparing an outline, thinking through themes and theories and ambitions. You can do one on the actual questioning, how to cross-examine a witness, that could be a session in and of itself. And teaching your team on how to cross-examine a witness using the rules I laid out on one factor per question leading, using, making sure that one question leads to the other and so forth. One session could be on how to defend your client's deposition. Another one could be at the actual deposition or maybe doing a mock deposition where you're dealing with an over steppers or obnoxious opposing counsel. And one of the partners is trying to push the boundaries and how a witness or how your attorneys can deal with that. But I think so important in all of this is that you have to train your people on how you want them to take a deposition and how to defend a deposition. How to use exhibits and what exhibits to use, how to cross-examine a witness. How to deal with an obnoxious opposing counsel. How to lay the foundation for mediation or for summary judgment. You know, what types of questions are you using? And a lot of this can be done by looking at your old cases. I'm not a huge fan of war stories, but they have their place. Thinking through a case where you took particularly effective deposition that led the foundation for mediation or summary judgment or trial. And showing your team what you did and the preparation that was required to reach that point. And why you asked the questions you asked and the order you asked them. And what you were trying to accomplish and how in fact you accomplished that and how you were able to use that favorably to achieve your objectives. Deposition is like exercise or like dieting. The more you do, the more reps you get in, the longer, the more consistent you are, the better you get at it. Working out your first day or month of working out, you're in a lot of pain or your discomfort, you don't really wanna do it. And eventually it becomes a habit. And over the long term you get bigger, you get stronger, you get faster. And depositions is no difference. It's doing the reps. Your first deposition, your first set of depositions aren't gonna be great. They're gonna improve our time. And that's something you have to explain your team. It's something you have to accept as a managing attorney. Like you're gonna teach your team how to take the deposition. And when you read the transcript and I suggest that you sit down after you get transcript back and you sit down with your team and go through what worked and what didn't. You're probably going to cringe from time to time saying, "Wow, I could have done this much better." But that's the process and it's kind of reflect back at the time when you're taking your first deposition, or depositions. And if you were to go back and still have them, you know, 20, 30 years later, I'm sure you probably did or asked or you know, pursued certain lines of questions that just weren't particularly effective or helpful and maybe they're even worse than the depositions that you're seeing your young associates do. So be patient, be considerate. This is a long-term process to become a very effective cross examiner. I've been doing this for 25 years and I wanna say maybe in the last five years I've gotten really good at it and gotten really effective as I continue to study and appreciate how the skill is being done and I continue to grow and become better at cross-examining witnesses of trying cases. And it's a lifelong process and that's something you have to understand and teach your people. So concluding thoughts. Effective deposition skills can be taught and learned. Every affirmation should make an effort to formulate their deposition skills, training program to improve quality control, work product and results. And again, there's a book that I have, it's a free book and I recommend that you take a look at. Again, it's on my website, miamimentor.com, where it's on my LinkedIn page under Frank Ramos Publications and I believe it's called, "Deposition Skills or Drills." And it talks about the skills that you need as a lawyer and how to teach them. And it goes through a number of exercises. I didn't include them here, you can find it there. But in terms of different exercises that you can sit down with your attorneys and run through with them in terms of you know, how to do that, maybe how to do a cross-examination. Maybe taking an old deposition and going through that with them, you know, coming up with a mock idea and getting them to cross-examine a specific witness. Teaching them how to ask one fact per question. Again, these are all things that take time to develop, to learn, to process, to implement. And instead of just leaving it to luck, leaving it to just letting your attorneys figure it out on their own. Be more proactive. Come up with a plan. Preferably a lunch and learn over five or 10 classes and for each of them have one attorney sort of lead the discussion. Have all your associates participate and try to imbue as best as you can, the skillset they need. For example, just knowing how to be an effective cross examiner is a skill that many lawyers don't have. Lawyers that have been deposing people for decades, I come across transcripts and it's like, what happened next? And what did you learn? And they're not really asking leading questions, they're not doing the deep dive, they're not pinning people down. They're not doing the funneling approach. And it's clearly that they never really learned how to do that. And so if your team from top to bottom has the appropriate deposition skills, it's a great way to improve quality control, a great way to improve outcomes for your cases. Great way to impress clients and great way to having them come back. Again, my name is Frank Ramos. This has been teaching deposition skills. Again, I walk into my website or my LinkedIn, you can reach out to me on either platform. I'm miamimentor.com or through LinkedIn. You know, make contact or follow me and you'll find a lot of resources there. Thank you and good luck.

Presenter(s)

FR
Francisco Ramos
Partner
Clarke Silverglate, P.A.

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                                                                January 18, 2028 at 11:59PM HST

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