67. Eight Steps for Handling Deposition Exhibits, with John Farrell

Depositions are a key building block in legal disputes, especially for cases that proceed to trial. According to veteran trial lawyer John Farrell, properly handling an exhibit so it’s admissible at trial is an overlooked skill that can, and should, be practiced until it becomes second nature. In this episode, John reveals eight crucial steps for handling documents that ensure your deposition flows smoothly and exhibits are admitted for trial. He breaks down the process step by step, gives the exact sample language that ensures exhibits are properly marked and admitted, and suggests ways to keep court reporters and judges pleased with your professionalism. 

Topics
3:59  Asking questions before marking a document 
5:35  When witnesses want to see a document first
7:48  Making deposition exhibits admissible at trial
8:30  Eight steps for handling exhibits: Step 1
9:36  Step 2
10:35  Step 3
12:08  Demonstrations of marking different documents
25:26  Step 4 , and helping the court reporter
27:59  Step 5, and the important question to ask your witness
29:12  Step 6, and two more important questions
32:15  Step 7
33:37  Step 8
35:35  Three-article series on depositions
37:23  Signoff questions

Quote
“‘Bears the word’ . . . is the safe phrase that judges like to hear.” John Farrell

Resources
John Farrell (bio)
Deposition articles (1, 2, 3)
Refreshing Recollection and Impeachment (article)