October 21, 2016 practice points

WWWAASSUUP: A Mnemonic for Effective Depositions

A useful and catchy mnemonic to help remember how to prepare for and take an effective deposition

By Hon. Mark A. Drummond

WWWAASSUUP!!!—it's a decade-old catchphrase for a popular series of commercials.

But WWWAASSUUP also provides a useful and catchy mnemonic to aid attorneys in remembering how to prepare for and take an effective deposition.

  • What does the witness know?
  • What does the witness not know?
  • Where is the missing information?
  • Ammunition for request to admit/motions.
  • Admissions that are clean for trial/SOJ.
  • Size up opposing counsel.
  • Size up the witness.
  • Understand the opposing party's theory.
  • Undermine escape routes.
  • Production—what else do you need?
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