Great tip Mike! What about the role of starting with admonitions in building comfort and rapport with deponent so they don’t take an adversarial tone from the jump?
I don’t really believe it wasting the admonition on that. There are plenty of ways to establish rapport. I often say “i appreciate your candor”, “clearly you cared about what happened” “wow you have a good memory”. I tell jokes.
Why do people care if they look stupid? I watched a deposition of Marcus Lemonis and he did great by all accounts. The guy didn't really answer anything of substance.
That’s a privilege. So you can’t force the answer. The issue is once they plead the 5th, then we move to exclude any evidence from the defense on that issue. It’s different in civil cases than in criminal cases
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Awesome & Thanks
Great tip Mike! What about the role of starting with admonitions in building comfort and rapport with deponent so they don’t take an adversarial tone from the jump?
I don’t really believe it wasting the admonition on that. There are plenty of ways to establish rapport. I often say “i appreciate your candor”, “clearly you cared about what happened” “wow you have a good memory”. I tell jokes.
I like that, thank you!
Why do people care if they look stupid? I watched a deposition of Marcus Lemonis and he did great by all accounts. The guy didn't really answer anything of substance.
How does the 5th Amendment play into this?
That’s a privilege. So you can’t force the answer. The issue is once they plead the 5th, then we move to exclude any evidence from the defense on that issue. It’s different in civil cases than in criminal cases