WWWAASSUUP: A Mnemonic for Effective Depositions

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?