10,000 Depositions Later Podcast

Episode 172: Second-Order Knowledge Examinations

May 8, 2026·15 min
Episode Description from the Publisher

In this episode, Jim talks about the value of "second-order" examinations - asking deponents not only what they know, but what others know (and what others know that still others know, which is a form of third-order knowledge). It's an incredibly valuable tool for ensuring you fully understand the actors, documents, and events in your cases. Garrity explains why witnesses will talk more freely about what others know than about what they themselves know, and wraps up with practice tips for litigators who are either taking - or defending against - second-order knowledge examinations.As always, thanks for listening!

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