Just saw this over at Overlawyered. (You read them right? They’re great.)
“Deposition Tricks: The Dirty Dozen” by Neil Dilloff of DLA Piper.
The following practice tips probably will be of the most use to younger litigators. To the more senior lawyers who use these tricks, this litany will resonate loudly.
- The Big Pause
- How Boring
- Mr. Nasty
- The Stick
- The Carrot
- The Fireside Chat
- You Must Be An Idiot
- Karnak (a/k/a ESP Questions)
- Slimy Questions
- The Motor Mouth
- The Idiot
- The Stall
For a rundown of each of these tactics download the brief 3 page article here.
Dilloff, Neil Joel, Deposition Tricks: The Dirty Dozen (July 2009). Maryland Bar Journal, Vol. 42, No. 4, pp. 48-50, July 2009; University of Baltimore School of Law Legal Studies Research Paper. Available at SSRN: http://ssrn.com/abstract=1616838