Paralegal Certification PrepLitigationMedium

During the discovery phase of a personal injury case, the plaintiff's attorney wants to obtain sworn testimony from a non-party witness who observed the accident. This witness is not expected to be uncooperative, but their testimony is crucial. Which discovery tool is most appropriate for obtaining this testimony?

  1. ARequest for Admissions
  2. BRequest for Production of Documents
  3. CInterrogatories
  4. DDeposition
Show answer & explanation

Correct answer: D. Deposition

A deposition is the most appropriate discovery tool for obtaining sworn testimony from a non-party witness. It allows for live questioning and cross-examination, preserving testimony for trial.

Why the other options are wrong

  • A. Requests for Admissions ask a party to admit or deny specific facts, not to provide open-ended testimony.
  • B. Requests for Production of Documents are used to obtain documents or tangible things, not oral testimony.
  • C. Interrogatories are written questions submitted only to parties, not non-parties.

Deposition

A discovery device in which one party's attorney questions a witness under oath outside of court, with a court reporter present to record the testimony.

  • Witnesses are sworn in.
  • Testimony can be used at trial.
  • Can be taken from parties or non-parties.

Memory trick: To get the full story, 'Depose' the witness and listen carefully.

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