Here's a deposition tip from ATLA that applies to both plaintiff and defense lawyers: "Don't Let the Witness Change the Story," by Michael L. Roberts.
During deposition, use a “chapter” format to control a witness and clarify the questions and answers the jury will hear later, when the witness’s deposition testimony is presented. This will minimize the witness’s ability to wiggle out of his or her admissions.
Announce the “chapter” topic when you begin a series of questions; at the end, ask the witness if there is anything else he or she remembers about the topic. Then tell the witness that you will move to a different topic.
Periodically restate and summarize what the witness has said. Boil it down to succinct sound bites that will be useful for impeachment and more easily played or read back to the jury.
You'll find more tips from ATLA here (remember to scroll down).
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