| name | deponent-coaching |
| title | Deponent Coaching Guide |
| description | Generates behavioral coaching materials for deposition witnesses, covering the SHAQ method, golden rules, difficult question handling, composure techniques, and phrase scripts. Use when preparing a witness for deposition, running a witness prep session, or creating take-home coaching materials. Companion to deposition-witness-prep-session. Applies to U.S. federal and state civil litigation. |
| author | CaseMark |
| author_url | https://github.com/CaseMark/skills/tree/main/skills/legal/deponent-coaching |
| license | Apache-2.0 |
| version | 0.1.0 |
| execution_mode | open |
| jurisdiction | us |
| practice | litigation |
| language | en |
Deponent Coaching Guide
Produces ready-to-use behavioral coaching materials for deposition witnesses: methodology, rules, difficult question handling, composure techniques, and phrase cards.
Prerequisites
- Witness identity and role — relationship to the matter
- Matter context — subject matter and claims/defenses at issue
- Anticipated difficulty areas — topics where the witness may struggle (optional)
Core Mindset
Open every coaching session with:
"Your only job is to tell the truth based on what you actually know and remember. You are not there to win the case — only to answer truthfully. If the truth hurts our case, tell it anyway. What we cannot recover from is testimony that isn't true."
The SHAQ Method
| Step | Rule | Key Point |
|---|
| Stop | Pause before answering | Don't formulate while the question is being asked |
| Hear | Listen to the full question | Wait for completion; ask for clarification if unclear |
| Answer | Answer only what was asked | Yes/no questions get yes/no answers — no volunteering |
| Quit | Stop talking immediately | Silence after answering is not your problem |
Example — Q: "Did you attend the March 15 meeting?"
- Bad: "Yes, I attended. It was about the quarterly review. About eight people were there..."
- Good: "Yes."
Ten Golden Rules
| # | Rule | Script |
|---|
| 1 | Listen to the complete question | Never interrupt; don't anticipate the ending |
| 2 | Clarify before answering | "What do you mean by [term]?" / "Can you rephrase that?" |
| 3 | Answer only what's asked | No explanations unless asked "why" |
| 4 | Always tell the truth | Even unfavorable facts — partial lies destroy all credibility |
| 5 | "I don't know" is acceptable | Use when you genuinely lack the information |
