One of the differences between a seasoned litigator and a novice is the ability to take total control of the witness, both at deposition and at trial. Inexperienced attorneys, including my former self, often let witnesses run from the question, or take them down irrelevant rabbit holes, or hide behind non-answers. But as we mature as lawyers, we learn to reign the witness in, to “let them know who’s boss”. We also learn not to take any crap from opposing counsel.
Here’s a recent example of “taking control” from a deposition I recently had. I was deposing a corporate witness in a convenience store slip-and-fall case. She was trying her hardest to weasel out of answering my questions. Look at how she tries to evade my questions: