Gain insight into deposing the opposing party's main witness.
When it comes to deciding which witness(es) to depose, always depose the opposing party’s main witness(es), be they fact or expert witnesses. Unless, of course, your trial order requires extremely detailed expert reports that the deponent is bound by, and you have bias and credibility depositions or testimony from outside sources. It's important that you lock in the factual information and agreements so you cannot be surprised at trial. This video reviews ways to get the deponent to agree to obvious concessions and discusses why you should videotape some depositions but never others.
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