The importance of discovery checklists
I’m a great believer that lawyers must use a checklist for every deposition they take no matter how experienced they are. If seasoned airplane pilots use checklists, lawyers should too. It’s too easy to get side tracked during a deposition and forget some area of questioning. What follows is an example of a verybasic and simplistic outline for the deposition of an eye witness in a damage case. I take an outline like this and revise it by adding areas…