Do not ask more than you need.
When planning the deposition it’s important to think of it as if It were a live trial testimony. You start with an introduction of the witness then cover factual information and case themes. Use legal terminology that meets your evidentiary standards and burden of proof. Re-ask if you do not get the required response initially. Make sure you ask questions that conform to the Rules of Evidence so you do not risk having them stricken later at trial. This video reviews these tips and also discusses witness attire and potential props.
Deborah J. Gander
Colson Hicks Eidson
- Partner at Colson Hicks Eidson since 2002
- Has dedicated her career to helping victims receive justice
- Board certified civil trial lawyer with more than $100 million in verdicts and settlements for her clients
- Represents clients who have suffered catastrophic injuries or who have lost family members; also represents clients who face financial ruin because of insurance company bad faith
- Has 20 verdicts exceeding $1 million
- Includes an award that was the largest ever in a Federal Tort Claims Act Case: $61 million for medical negligence at a Naval hospital, and was the first time in history the U.S. government was held liable for the acts of a doctor it alleged was an independent contractor
- Achieved the highest rating in the Martindale-Hubbell Law Directory, and includes her in the Martindale-Hubbell Bar Register of Preeminent Women Lawyers
- Received the “Most Effective Lawyer” award for civil litigation in 2006 from the Daily Business Review
- Has had two of her verdicts receive the Daily Business Review’s “Verdicts Hall of Fame Award”
- Has been repeatedly named one of the “10 Best Attorneys in Florida” by the American Institute of Personal Injury Attorneys
- Is an elected member, executive board member, and President of the Miami-Dade chapter of American Board of Trial Advocates
- Co-chaired the Civil Litigation Committee of the Dade County Bar Association
- Continues to lecture for organizations including the American Bar Association and American Association for Justice
- Was a law clerk to the Honorable Peter T. Fay, Eleventh Circuit Court of Appeals
- Graduate, magna cum laude, University of Miami School of Law; served as an adjunct professor there for several years
- Can be contacted at 305-476-7400 or [email protected]
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