It is not always clear how a deposition or written discovery responses can be used by a party during an evidentiary hearing or trial. The applicable discovery rules provide guidance, but frequently the judge is unsure of what is and is not permissible, and whether the response even needs to be shown to the witness or whether the witness or opposing party is allowed to explain or rebut a discovery response. This presentation will discuss the permissible use of discovery responses and depositions under the applicable rules of civil procedure. Additionally, there will be a discussion of practical considerations for use of the discovery. Finally, this presentation will provide suggestions on methods to make the discovery responses more effective or useful at a hearing or trial.