The Jury Is Out

EP 718: Deposition Tips, Part 1: Style, Approach, and Brainstorming Before You Ever Ask a Question

September 2, 2026·29 min
Episode Description from the Publisher

Hosts John Simon and Tim Cronin dig into how to read a witness in the first 15 minutes, when to be deferential versus direct, and why walking in with a rigid game plan can cost you if you're not willing to throw it out in the first of a new multi-part series on deposition strategy. They break down what separates attorneys who simply gather information from those who use every deposition to actively build their case and share real war stories from decades of practice. The episode covers five tips on style and approach and four tips on brainstorming before you even build an outline, laying the groundwork for the deeper series ahead: deposition goals, thorough preparation, in-the-room tactics, and cross-examination strategy. As John and Tim put it, the case goes as the deposition goes and this episode explains why.

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