By Marci Glover


Every lawyer will have to ask questions either to their client or to the opposition to be able to achieve their goal. If you are a lawyer who handles commercial litigation NJ, then your basic goal is to have the other side's client to get deposed or impeached. Getting the other side's client deposed or impeached is your success.

Preparing questions that will help out with the case is one of the works of an attorney. As the attorney, you will need to make sure that you can achieve the goal of getting the other party's client impeached or deposed. Here are a few of the killer questions you need to prepare beforehand to achieve the goal properly.

Ask relevant questions of prior conviction. You better ask the other party's client if there was an instance in the past where he or she has been arrested. You should then follow it up to ask about convictions way before. While the other party's counsel might react overboard over this kind of question, go ahead with this. Prior convictions are valid for impeachment.

Questions about depositions. There will be a big turn around if the said individual has experienced prior deposition. After all, this will establish the individual as someone who is unfit for the said position. It will make it easier to handle your case if the individual has a prior record for deposition.

Ask relevant questions regarding acquaintanceship. The person may be an acquaintance or a familiar face to the witness. You need to ask both the witness and the other party's client about whether they have seen each other before the events of the case. This way, you can uncover any connections between the two individuals.

It will be useful for your side to know whether the individual you are inquiring has met up with the other side's counsel before the said deposition. You should always take note of the number of meetings that occurred, where they were held, and how long each of the meetings lasted. With this information, you can dismantle one's claim of independence.

Know whether the individual you are inquiring has signed a written statement, made a recorded statement, or spoken to the media about the events of the lawsuit. Also, do not forget to ask whether the individual has posted any statements about the said events on the Internet. Verify the answer of the individual. If you find out that they are lying, you can use it to your advantage.

Ask relevant questions about the person's preparations before the deposition. You can always assume that the person made some preparations beforehand to handle the deposition. Since this is the case, then you should ask about it. It will allow you to have a glimpse of the person's weaknesses. It can be used to your advantage then.

Remember that these are not the only questions you will need to ask the person. Get to know more about the person's personality, principles, and other aspects. It will allow you to establish the fact that the person is worth deposing or impeaching. Prepare your case to obtain success.




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