EP 719: Deposition Tips, Part 2: 12 Goals to Accomplish in Every Depo

Co-hosts John Simon and Tim Cronin move from style and brainstorming into the concrete goals attorneys should have walking into any deposition. As John puts it, if a deposition isn't accomplishing one of these goals, it may be worth asking why you're taking it at all. John and Tim break down the list of tips, from establishing the elements of your case and eliminating claims and defenses, to boxing witnesses into fixed answers, flipping expert opinions before they're given, and establishing safety rules the other side has to agree apply. Along the way, they share detailed trial stories: a trucking case built around the true purpose of a trailer's rear guard, a corporate representative deposition that quietly eliminated every defense in a wheel failure case, and a five-minute deposition that ended a case before it truly began. The episode also digs into the discovery side of depositions most attorneys underuse.