There is a famous mathematical concept called the Infinite Monkey Theorem. The theory suggests that an infinite number of monkeys sitting at an infinite number of typewriters for an infinite amount of time will ultimately produce the complete works of Shakespeare. While this might be mathematically true, there are more efficient ways to get a copy of Hamlet. There are also more efficient ways for litigators to work through the discovery process than casting the widest possible net.
Most clients have litigation budgets. But even if there is no actual budget, there are limitations on the amount of time and money a client is willing to spend on the resolution of a dispute. Of course, there are exceptions. The late Nicholas Katzenbach, general counsel of IBM, once told a concerned shareholder that there was no limit on the expense IBM was willing to incur to defend itself against the suit by the U.S. seeking to “break it up.”
2. Ask surgical questions
The preamble to any deposition can be deadly. Some lawyers call it the dredge: State your name, tell me where you were born, where did you attend school, what courses did you take, did you participate in any extracurricular activities, what training do you have and so on. Start at the beginning and work your way to the end. Cover the entire life of the deponent. The key question in the "dredge" examination is, "and what happened next?" Or, just for the sake of variety, "and then what did you do?" That's the convention.