Draw the Witness’s Attention Where You Want, 
At The Right Time

A key to the success of your deposition is focusing the witness's attention where you want them to focus, and at the right time. Being able to move through an exhibit in the background – and only introducing a new section at the appropriate moment – allows you to maintain control over the flow of the deposition, while strategically introducing new information at a time that best supports your line of questioning.

When screensharing a PDF in Zoom, you’re sharing everything. You do not have the ability to navigate privately and be strategic in the introduction of new information.

Here are three ways to not give your hand away until you're ready to ask your next question:

Tactical Impact – By quickly and strategically jumping to pages in a large document at critical moments, you may provoke stronger reactions, emotional responses, or inconsistent statements, which can strengthen your position.

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Avoiding Witness Preparation – Unsure where a critical diagram is in a document? Use a thumbnail view in the background to locate the right spot to go to next. Showing your movement through the document too soon may reduce the witness’ spontaneity.

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Testing Witness's Recollection – Keyword search a word or phrase privately. By asking a pointed question before moving to a different section of the exhibit, you can gauge the witness’s recollection or knowledge of the subject matter.

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