I would love to take depositions right now. Start at the bottom.
Describe for me the events leading up to moving the barricades back and allowing people onto Capitol grounds.
You were scheduled for security detail on Jan. 6. Who made that schedule?
Who determines the number of officers on a detail? How do you find out about those assignments? Who tells you?
As an officer, what input do you have into staffing decisions? What do you do if, in your judgment, the staffing is inadequate for the security needs?
Move up the chain until someone admits it was their decision to have so few capitol police officers on duty yesterday.
That person may have to assert their 5th Amendment right not to testify in self-incrimination. I don't mind at all.
Explain your planning process for security when you know large demonstrations are likely. Describe how you planned in July 2020. Describe how you planned for Jan. 6, '21.
For each thing the deponent lists: Why is that the practice? Why did you do it like that on [relevant day]?
What is the protocol for adjusting to add security if it starts to seem like more is needed? When do you call in reinforcements?
What agencies are supposed to be on standby to assist you? Who is responsible for those decisions? Who is responsible for making the phone call?
On Jan. 6, when did you decide reinforcements were needed? Why then? Why not earlier than then? What triggered that decision? Who made that call? Who did they call? What was the response?
Practice note: I don't believe in using leading questions during depositions, except for bounding questions (confirming what the deponent has already said)
Depositions are for nice, calm, slow, soporific, totally boring info gathering & commitments

which you then use to SLAY the witness in motions/trial
You can follow @Miz_Rosenberg.
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