How to take a deposition — try the 'triple pass' technique

Lawyers’ Forum

By Thomas N. Osran

Thomas N. Osran is a senior assistant general counsel at the Chicago Housing Authority.

Posted October 4, 2019 3:33 PM

Updated October 7, 2019 8:46 AM

I was at a law school alumni meet-and-greet when I met a young litigator, only six months out of school. She worked for a small defense firm and was nervous about taking her first deposition.It was of a treating doctor.She asked me for some tips.First, I asked her, what is the purpose of this deposition? What do you hope to get out of it?She wasn’t sure.I explained that the first goal of any deposition is to find out what the witness has to say. You want as much of an unvarnished truth from the witness as you can get …

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