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When preparing a witness, don't waste time teaching them combat tactics. Get to the hard stuff.

Handle deposition objections like you handle a snake in the cockpit: ignore the distraction and fly the plane. Don't argue with counsel; simply focus on the witness and get your answer.

Effective depositions rely on persistence. Rephrasing and revisiting questions over time usually breaks evasion. Depositions reward stamina, preparation, and practice.

When a witness gives a long, muddy answer with an admission inside, it’s unusable for cross-exam. Break the answer into short, controlled questions to isolate clear, precise admissions you can actually use.

Most deposition questions are “mud” used to move the witness and build context. Stay casual there. When an admission appears, switch to precise, clean questions to extract a usable “crystal” for cross-examination.

Depositions are valuable only if answers can be reused on cross-examination. Discovery or motions don’t change that. If testimony can’t become a clean cross question, it isn’t truly usable evidence.

Frontier AI models improve so fast that studies comparing them to legal-specific AI become outdated almost immediately. Retesting recent benchmarks shows general models already match or exceed earlier reported gaps.

Lawyers’ claims that AI makes them more efficient may be unreliable. Evidence shows people often misjudge AI’s impact on their own productivity. Firms should rely on objective data, not self-reported impressions, when de

LegalTech favors “direct” AI control, but its benefits are shrinking as frontier LLMs improve at prompting, workflows, and security. The “inverted” model is viable and likely to gain adoption despite vendor resistance.

Delegating legal work to LLMs can save time but costs learning. Prefer: you read/outline; AI summarizes and fills tedious parts. Ask not only “can AI do it?” but “am I OK not doing it?”

LLMs summarize well but default to average analysis. That makes them useful for baseline work, but not a substitute for the fresh, above-average insight junior lawyers often provide.

To get clean yes/no answers, don’t start with the impeachment question. Use a series of simple, uncontested yes/no questions as a “runway.” This makes it much harder for a witness to evade the key admission.

Don’t “chat” with AI like a junior lawyer. Long conversations degrade results. When output slips, start a new chat: rephrase, add context, or break the task into smaller steps.

On minor points, impeachment isn’t always optimal. Refreshing recollection can fix a “light no” while preserving flow, tone, and witness cooperation.

Refreshing recollection is riskier than impeachment but useful when done carefully. It can pressure a witness, correct a denial, and keep control without escalating conflict.

Impeachment is a skill learned by practice, not rules. Learn the mechanics first, then understand how evidence rules—especially hearsay and prior statements—apply.

Effective impeachment requires precision, not improvisation. Match prior statements exactly, control the witness through tight logistics, read the contradiction clearly, then move on.

Pasting document clips into your outline keeps everything in one place. It eliminates binder juggling, saves time, and helps maintain rhythm and control during depositions.

Writing every question in advance exposes risks early, prevents surprises, and builds disciplined deposition skills. It sharpens judgment before the room, not inside it.

Strong depositions start with disciplined prep. Define clear goals for each outline section to avoid drift, stay focused, adapt in real time, and use limited deposition time strategically.

Transcript software is essential right before trial for designations and video clips. For most of a case, PDFs or print are faster and more practical for reading, prep, and motions.