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Must Questions continued...

- Ask if they have a driver’s license, if so ask to see it and read it into the record or jot down the information.

- Ask if they have ever been arrested? If the the answer is yes the next question should be, Have you ever been convicted? Now while the other sides attorney will probably object up one side and down another these questions are very legit and allowed in court.

- Ask if they have ever been in a deposition previously? This appears to be an innocent question but if the deposed answers affirmative the next question should be, Have you ever been called to court to give testimony? and then ask if they have brought a lawsuit against someone or had a lawsuit brought against them. Why these questions? Because previous testimony in other suits can have a huge amount of information of past indisrcetions.

- Ask if they have ever had any doings with the opposing side the before the actions of the lawsuit came about? This is to see if there may be bias of a witness.

- Ask if they have ever seen or talked with the opposing counsel prior to this deposition. If so finf out all the who, whats, when and wheres. The information gathered here can knock down any pretensions of separation.

- Ask if they have ever talked with anyone or written anything down in regards to the lawsuit? If so findout how it was dissentated by either newspaper, the internet etc. You can always do a search engine query prior to the depostion to see if the witness is lying.

- Ask if they have ever looked over or heard any of the witness statements of the deposition. Also, looked at any information from statements or information regarding the lawsuit.

- Ask any and all the things they did to prepare for the deposition. Their response can give you an idea of some of their subject matter they may be lacking in and areas you did not know about.

- Ask if any other person was present when they met with their attorney. If so the witness might have waive his or her attorney-client privilege.

- Ask how they found the attorney to be an expert witness? This can open up a huge can of worms on past involvements or self interests
of the opposite attorney.

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