As a general principle, the first response of a witness is never everything they know or feel about a subject. That’s why one of the fundamental skills for good depositions is “exhaustion”, asking “what else”, “tell me more” etc. until we are satisfied we have enough to move on.
Three years ago, I started studying clean language at the behest of one of my fellow faculty members (Robyn Wishart) at the annual Advanced Deposition College. When a witness doesn’t really want to explain something it is very effective. This topic will be part of our 1 day workshop on Advanced Depositions at TLU New York on September 20-22. More information here.
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