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Create outline for deposition
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After mapping out your basic plan about what information you need from the deponent, make a more detailed checklist of the testimony you intend to elicit. Every lawyer has his or her own system for preparing deposition questions. Some attorneys handwrite either the areas of testimony or the exact wording of key questions. Some outline a lengthy checklist on the computer. Others create an outline that fits on one sheet of paper. More experienced attorneys have the ability to map the questions in their minds.

Whatever method you use, your questions should not get in the way of the testimony. For example, your witness may volunteer information right away, but that information may concern the end of your outline. If you insist on asking questions in order of your outline, the witness may be less forthcoming. Stay on course, but be flexible enough to explore when appropriate.

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