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CHECKMATE: Develop A Winning Opening, Middle & Endgame For Any Witness Exam - March 19


• Your opening questions help set the stage to fail or to succeed, and your early moves will define your outcomes.

• Your ease with handling exhibits (especially during the COVID-age of ZOOM depositions), and your strategy regarding when to use them, should not be underestimated.

• Hone your skills at exhausting the witness' recollection, and seal off the exits for that witness.

• Prepare to examine the "forgetful" witness ... and capitalize on their selective amnesia.

• Never let anyone tell you not to have a script - strategically created scripts allow you to plan for any potential response from the deponent, and pursue follow-up questions, without losing sight of your objectives, or missing a beat.

• Use checklists to ensure you not only obtain the evidence you need to build your client's case but also make certain you devastate the opponent's defenses.

• Find an opportunity for a "sound bite" before concluding.



Amy Van Ostrand

Rowe & Hamilton, Indianapolis


1 CLE - Friday, March 19; 12:15 P.M. - 1:15 P.M.



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