I know that normally an attorney wil ask the questions they plan to ask at trial at the deposition to reduce the chance for surprises, such as an answer they don't expect.

However, suppose there is a question that is a potential zinger and the litigator does not want the witness to prepare a response. In that case, is it wise to not alert the witness to the existence of the question and spring it on him at trial, or is that pretty much not done?


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