Hey Reader,

We’ve gotta tell you about one of our favorite moments that just happened in a depo.

A little context…

We’d been helping an attorney prepare for a 30(b)(6) corporate witness.

As we built the deposition, Steve and I found a few things we definitely wanted marked as exhibits.

Cut to the deposition and our attorney pulls one up.

Another document came out…

So what exactly was in these documents that suddenly had defense counsel so interested?

The company had publicly spelled out:

• How [X] should work.
• What should happen when [Y].
• Who was responsible for [Z].

Basically, a roadmap of the things that could have prevented this case from happening if they had followed what they published.

That’s why we don’t stop our research at the discovery production.

Because some of the best deposition material is hiding in plain sight.
​
Their "our values" page.
FAQs.
Press releases.
Job postings.
Blog posts.
Code of Conduct.
Annual reports.
Podcasts.

🔥HINT: Don’t stop at the main menu of their website. Check the footer. That’s where a lot of the good stuff hides.

When you find it, download it. Screenshot it. Save it.
Then build the questions.
It’s one of the easiest ways to start establishing what a company should have done.

Their website may not establish the legal standard.

But it can give you their own words about how things are supposed to work:

• What did they say should happen?
• Who did they say was responsible?
• What did they tell customers, employees, and the public they cared about?

Corporate defendants spend a lot of money telling the world how careful, responsible, and safety-conscious they are.

Those words become a lot more interesting when their conduct tells a different story.

So before your next deposition, go digging beyond the docs they gave you.

And if you’re short on time or not sure where to start—hand us the shovel.
We’ll do the digging and build the deposition.

​[Find out more]​

Your internet-sleuthing trial consultants,

P.S. If opposing counsel’s first question is, “Where did you get that?” you probably did your homework. Extra points if the answer is, “Your website.”