How to Handle Evasive Witnesses in a Deposition | Deposition Strategies with Mike Alder
Автор: AlderTalk
Загружено: 2026-02-21
Просмотров: 238
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Evasive witnesses can destroy a deposition if you don’t know how to handle them.
In this episode, veteran trial lawyer Mike explains how to handle evasive witnesses in a deposition and why most deposition strategy fails before the first substantive question is ever asked.
Many attorneys treat the deposition admonition as a routine script. Mike explains why that approach is wrong — and how to use the admonition strategically to control the deposition, reduce “I don’t remember” answers, and increase truthful testimony under oath.
With more than 30 years of trial experience and over 150 trials, he breaks down:
• Proven deposition strategy for dealing with evasive witnesses
• How to respond to “I don’t recall” and incomplete answers
• The legal standard governing the scope of discovery in a deposition
• How to frame testimony under penalty of perjury
• When to file a motion to compel or seek sanctions
• Why depositions matter more than trial in most cases
This episode is essential training for trial lawyers, litigators, personal injury attorneys, and law students who want to improve deposition skills and learn advanced deposition techniques that create leverage.
If you want to conduct stronger depositions, control evasive testimony, and maximize discovery, this breakdown of real-world deposition strategy will change how you approach your next witness.
Because most cases are decided long before trial.
And depositions are where that happens.
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About AlderTalk:
Michael Alder shares his knowledge gained from 30+ years in litigation in Personal Injury, as well as general business and life advice. His tips and conversations are dedicated to lawyers of all experience levels, and anyone beyond the legal space looking for business or life advice.
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