Depositions 5 of 5: Questioning Techniques
In the old Hollywood "mobster" movies, the gangsters referred to their lawyers as "mouthpieces." The gangsters always seemed to be worried that someone would "rat them out" or "turn state's evidence" against them. They were concerned that "this someone" would "sing like a canary" to the authorities. Such potential threats were often "rubbed out," not "cancelled."
There are tried-and-true methods or techniques to get a witness to "sing like a canary." These include the "funneling technique," the "listing technique," the "lima bean routine" of questioning, as well as various others. Unfortunately, these are not usually taught; the only way to learn these has been "the hard way," that is the college of hard knocks. The basics, when executed properly, every time, are what make us professionals. Sign up to learn these fundamental questioning techniques.
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3035 Cleveland Ave., Ste. 205
Santa Rosa, CA 95403
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Michael G. Watters
O’Brien, Watters & Davis, LLP
Mr. Watters is a veteran trial and appellate lawyer. He has tried more than 40 jury trials to verdict, more than 30 court trials to judgment, handled many arbitrations, as well as more than 75 appeals.
He has taken or defended more than 1000 depositions in a variety of cases including medical malpractice, personal injury, wrongful death, products liability, employment litigation, real estate fraud, fraud in the sale of businesses, partnership disputes, family law, elder financial abuse, probate and trust litigation, etc.
Mr. Watters has been actively involved in ADR. He was on the AAA Commercial Arbitration panel for many years. He was a Mediator with the American Arbitration Law and Mediation Center. Mike was a long time Settlement Conference Panelist. Michael has also been a court appointed Discovery Referee.
He established a formal litigation training program at his firm and trained more than a dozen local trial attorneys including the first woman hired to do civil litigation in the county, the county’s first woman Superior Court Judge, two Deans of Empire Law School, and several other lawyers who also became Sonoma County Superior Court Judges.
Michael received his B.S. and M.B.A. from Cal and his J.D. from Hastings. Michael Watters has presented a number of SCBA MCLE programs including topics on the deposition.