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24 5 322 DEPOSITIONS Administrative Rules of the State of Form

24 5 322 DEPOSITIONS Administrative Rules of the State of Form

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if you ever have to take a deposition then you need to know the most important questions number one ask questions that eliminate the Escape Routes responses that include to the best of my recollection generally basically not that I can think of number two ask questions that close out all those exits you cannot let the witness have an exit at trial by saying they did not remember these questions are what else happened where can you go that can help you remember as you sit here today have you told us everything you know and recall number three ask those closeout questions on every topic you must close the funnel on every line of questioning so they cannot change their testimony at trial we must pin them down and lock them in or else the deposition is wasteful

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