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What should be avoided in note-taking for a deposition?

  1. Documenting bare essentials

  2. Referring to your previous reports

  3. Taking notes during the deposition

  4. Creating a summary after the deposition

The correct answer is: Referring to your previous reports

The correct choice focuses on the importance of maintaining the integrity and spontaneity of testimony during a deposition. Referring to previous reports while taking notes can introduce inconsistencies or influence the responses of the individual being deposed. This is because preformed opinions or information from former notes can inadvertently lead to leading questions or suggestive phrasing, potentially compromising the validity of the testimony being captured. In contrast, documenting only the bare essentials is appropriate for ensuring that key information is captured without overwhelming details. Taking notes during the deposition itself, while fostering an understanding, should be done with caution and attentiveness to the process. Lastly, creating a summary after the deposition adds value by compiling information, clarifying the context, and synthesizing findings without affecting the live testimony. Thus, the choice to avoid referring to previous reports is rooted in preserving objective and reliable documentation of the current deposition process.