Topics covered include: classic example of the question-dodging witness; cross-examiner's two lines of appeal to opposing attorney; combating obstructionism prior to the deposition day; real purposes of admonitions; best admonitions & their rationale; corollary to the “cooperation” admonition; obstructionism re the deposition breaks and obstructionism re the production of documents at deposition.  Also covered: the four legitimate grounds re the instruction “Don’t answer!”; the two deposition “cultures”; cross-examiner’s four failures re opposing attorney's objections; question-dodging and recording the deposition: the up-sides and the down-sides.  Case studies will be used to examine: A “memory” claim: the toughest answer to prove is a lie — Why depose? How depose? Word-hawking skills; dramatically define witness’s relationship to the “forgotten” info; acquisition of info recent; memory revived; prior training or experience with subject; witness's this-case motive to "forget"; selective memory; dramatically define the purported limits of witness’s memory; attacking the "I don't remember" that seeks to reserve a bad surprise for trial; deposition admonitions; disabling memory-triggers; looping deponent's memory limits; making a speech to the jury and the get-outta-deposition card