Preliminary Sections

• Author: Evan Schaeffer
• Pages: 1-48

DEPOSITION

CHECKLISTS AND STRATEGIES

BY T. EVAN SCHAEFFER

HIGHLIGHTS

Deposition Checklists and Strategies gives you thousands of deposition questions for crucial witnesses: treating physicians,

corporate representatives, insurers, experts, defendants, and plaintiffs.

The most recent edition features—

A COMPLETE DEPOSITION TO PRESERVE TESTIMONY FOR TRIAL OF PLAINTIFFS’ MEDICAL EXPERT

IN A PHARMACEUTICAL MASS TORT.

In this contentious videotaped deposition, the expert witness testif‌ies that the defendant pharmaceutical company

knew that its drug was not as safe and effective as it told regulators at the FDA. The lawyers spend a lot of time objecting

and arguing among themselves.

20 NEW PRACTICE TIPS:

• When Opposing Counsel Is Older, Smarter, or More Prepared

• Form Discovery Is Just a Starting Point

• The Importance of Organized Files

• The Witness Often Takes His or Her Cues from You

• Using This Book’s Appendix to Save Time and Money

• Think About the Experts First

• Asking the Question, “Who Would Remember?”

• One Sign You’re “Winging It” at a Deposition

• Assessing the Defense in Light of Your Own Story

• A Stipulation for Standing Objections

• “Help Me Understand This”

• Never End a Deposition Prematurely

• Ask the Witness to Explain Technical Jargon

• Learn the Technical Jargon Yourself

• Be Able to Identify and Use Every Sort of Question

• The Dangers of an Ambiguous Answer

• Tips for Appearing More Experienced

• Controlling the Witness Who Rambles

• Sometimes You Should Save the Best for Last

• Be Humble When Assessing Your Case

AND MORE!

We Welcome Your Feedback

Our most useful source of improvements is feedback from our subscribers, so if you have any comments, we would

be delighted to hear from you.

Revision Editor

James Publishing, Inc.

3505 Cadillac Ave., Suite P-101

Costa Mesa, CA 92626

Visit us on the Internet at www.jamespublishing.com.

DEPOSITION

CHECKLISTS AND

STRATEGIES

T. EVAN SCHAEFFER

Contact us at (866) 72-JAMES or www.jamespublishing.com