Before and after. Today, the question that answers itself, badly.
This one gets asked in a deposition room somewhere every hour of every working day:
“Isn’t it true that you were tired that night because you had worked a double shift, and that you failed to check your mirrors before backing up?”
Let’s operate.
Pass One: Count the Facts.
Tired. Double shift. Mirrors. Backing. Four facts wearing one question mark. The witness picks the softest one and answers it alone: no, I was not tired. Read the transcript later and the no looks like it denied all four. You built the witness an exit and held the door.
Pass Two: Rebuild It as Stairs.
“You worked a double shift that day?”
“Sixteen hours?”
“That night you backed the truck out of the yard?”
“Before you backed up, did you check your mirrors?”
One fact per step. Each answer locks before the next question arrives. No trickery anywhere, which is the point: the stairs just go up, and by the top there is nowhere left to stand. Read aloud at trial, a staircase sounds like a confession assembled one step at a time.
Pass Three: Know Which Deposition You Are Taking.
The staircase locks down. It does not discover. When you still need to learn the case, the questions open instead: who was there, what happened next, tell me about the yard. Open questions to learn. One-fact questions to lock. Run them in the wrong order and you will leave the room with neither the knowledge nor the admission.
Why It Matters.
A deposition is not a conversation. It is the manufacture of trial testimony, one page at a time, and the product is the transcript. Compound questions make blurry pages. Blurry pages impeach nobody.
