Way back in 2015, we published our first edition of the most comprehensive set of opening questions for your next deposition, including follow up matters, common procedural mistakes in depositions, and the 41 questions to ask about any pertinent document.  The response was positive, which we appreciate!  In light of other depositions of ours over the past three years, and changing practices among business people (including the pervasive use of texts for everything), and more recently, the use of text-and-email-destroying-applications, we gave this list an upgrade, and decided it to publish it again for your use.

We hope you find this useful, time saving, and helpful in getting to the truth of things in your next deposition – it is located here in MS Word so you can drop it into your next deposition script in as much detail as you want.

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