The basis for an answer, the limits of memory, and when a witness first learned about events. This concentrated Q&A drill runs at 160 WPM for 5:34 (minutes:seconds).

• Recurring words and phrases: “basis”, “memory”, “remember”, “recall”, “personally observed”.
• Recurring question forms: “What is your basis for saying”, “What is the basis for your answer”, “When did you first learn”, “As best as you can recall”, “Are you saying your memory”.
• Recurring witness answers: “That is my present memory.”, “That is my recollection today.”, “That is what I recall today.”, “What I remember now.”, “No, I can't remember.”

Examples from the transcript: “What is your basis for saying you remember the telephone call?”, “When did you first learn about the preparation of the written report?”

Common deposition language returns throughout the take in changing combinations, with short, varied, one-sentence witness answers. Yes and No appear both alone and within useful answer constructions. Practice hearing and writing the words without relying on predictable context.

See more of the Q. and A.

What you receive

Included download: one ZIP containing the MP3 audio, matching Word transcript with Q. and A. labels (.docx), and Woodshedder-ready text (.txt). Digital files only; no physical shipment. Woodshedder access is sold separately.

How to use it

Listen once, then write the take.

Compare your notes with the transcript.

If you use Woodshedder, load the included text there for another practice pass, then write the dictation again. Note your progress and areas for further practice.

Who it is for

Use this when you want focused practice with deposition-style question-and-answer language in the edition or editions listed above.

Browse all practice dictations. Add Woodshedder access separately when you want to load the included practice text into the browser tool.