| name | deposition-questioning-techniques |
| title | Deposition Questioning Techniques |
| description | Generates deposition question sequences using six core examination techniques (Funnel, Boxing-In, Looping, Three C's impeachment, evasive witness handling, admission ladders). Use when preparing deposition outlines, building question sequences for specific topics, impeaching with prior inconsistent statements, or controlling evasive witnesses. |
| author | CaseMark |
| author_url | https://github.com/CaseMark/skills/tree/main/skills/legal/deposition-questioning-techniques |
| license | Apache-2.0 |
| version | 0.1.0 |
| execution_mode | open |
| jurisdiction | general |
| practice | litigation |
| language | en |
| tags | ["analysis","checklist","drafting"] |
Deposition Questioning Techniques
Reference and question-sequence generator for six core deposition examination techniques.
Prerequisites
- Identify examination goal per topic (discover, lock in, impeach, build admissions, control)
- Gather available documents and any prior inconsistent statements
- Have a topic outline ready — this skill converts outlines into question sequences
Technique Selection
| Goal | Technique | Question Type |
|---|
| Learn new information | Funnel Method | Open → Targeted → Closed |
| Lock in / exhaust testimony | FWD Close | Closed, exhaustive |
| Maintain control | Looping | Closed, using witness's words |
| Impeach prior statement | Three C's | Commit → Credit → Confront |
| Build inescapable admission | Admission Ladder | Short leading, one fact each |
| Handle evasive witness | Redirect + Looping | Yes/No redirect, repeat |
Technique 1: Funnel Method
Open → Targeted (6Ws+H) → Closed lock-in
- Open — "Tell me about… / Describe… / Walk me through…" then stop. Use silence. Do not interrupt.
- Targeted — Apply Who / What / When / Where / Why / Which / How to each thread from the narrative.
- FWD Close — Before leaving any topic:
- F: "Any fact about [topic] you haven't told me?"
- W: "Anyone with knowledge you haven't mentioned?"
- D: "Any document you haven't identified?"
- "Is that everything? Are you sure?"
FWD close prevents witnesses from surfacing new information later and supports fabrication arguments for late-disclosed evidence.
Technique 2: Boxing-In
Eliminate alternative explanations before confronting with damaging evidence.
Sequence: Commit → Close escapes → Confront
Example:
- Commit: "The decision was based solely on qualifications, correct?" / "Not on age or any protected characteristic?"
- Close escapes: "That was your understanding at the time?" / "Nobody told you something different?" / "You communicated it was qualifications-based?"
