It has two purposes: To find out what the witness knows, and to preserve that witness' testimony.
If not, the case will go to trial where the deposition, even if its not mentioned, will play a huge role.
You should try to limit the deposition record to the witness's testimony and the important discussions between counsel.
If all goes well, the witness will show up and everything will proceed smoothly.
Once you start asking a witness about unpleasant things they tend to become less inclined to volunteer information.But it's best not to get into the habit of doing this too much.Think impeachment at trial.See, federal Rules of Evidence, Article viii.It often helps to consider if you are: (1) trying to just gather information; (2) getting specific betsoft online casinos usa admissions of key facts; or (3) preserving testimony for later use at trial.Usually the deposition examination should proceed chronologically, that is, from a point early in time to more recent events.
Most witnesses have no trouble understanding your theme.
And when you make form objections you should make it your practice to state briefly what the objection is (unless, you are using it to simply 'nudge your own witness which of course you aren't really supposed to do).
This will make it difficult for them to claim ignorance if they later change their story at trial.
(I am not advocating being obnoxious, however.) Also, you might be trying to find out what the witness does NOT know and cannot possibly testify to later." Reader #4 "One suggestion: include some information about how the permissible grounds for instructing witnesses not to answer.This is usually done when the deponent is very ill and may not be well enough for trial.If you find witnesses having trouble grasping your themes then you are probably not using simple themes.A deposition is the taking of an oral statement of a witness under oath, before trial.To that end, it's important both to make an evaluation of the witness and to make an impression on the witness that favors settlement.In reality, the deposition procedure prevents this from happening.It should be noted that the direct and cross-examination of a witness can become heated, but this is even more true in one particular case.