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. 

Topics3:59 Asking questions before marking a document 5:35 When witnesses want to see a document first7:48 Making deposition exhibits admissible at trial8:30 Eight steps for handling exhibits: Step 19:36 Step 210:35 Step 312:08 Demonstrations of marking different documents25:26 Step 4 , and helping the court reporter27:59 Step 5, and the important question to ask your witness29:12 Step 6, and two more important questions32:15 Step 733:37 Step 835:35 Three-article series on depositions37:23 Signoff questions Quote“‘Bears the word’ . . . is the safe phrase that judges like to hear.” John FarrellResourcesJohn Farrell (bio)Deposition articles (1, 2, 3)Refreshing Recollection and Impeachment (article)