There are certain questions you should consider asking in almost every discovery deposition. Add the following issues to your standard outline or use them to anticipate your opponent's questions when your are preparing witnesses to be deposed.
- The standard preliminary questions (see related post, "Preliminary Deposition Questions: What's Their Purpose?");
- How the witness prepared for the deposition;
- Statements by your client that the witness heard;
- The identity of other witnesses;
- Statements made by other witnesses;
- The witness's relationship to other witnesses in the case;
- Conversations about the incident, lawsuit, or deposition;
- Admissions, i.e., testimony that will bolster your case.