To impeach, you first get a bad fact that contradicts a prior statement.
You then must credit the prior statement, very thoroughly. Read the litany, don't just ask if
You can then ask for permission to approach, show opposing counsel, approach, credit it to ensure that this is the "sworn statement," ask if he just said the bad fact, read the deposition, and ask if read correctly.
- Crediting is a bit different, as you then have to bring out why such a fact should have been in the prior statement. Focus more on completeness, not accuracy. Then instead of reading it, just say "Nowhere in this sworn statement did you mention X, did you?" Otherwise it is the same though.
Impeachment is usually by deposition but sometimes prior trial testimony.
You can only impeach a witness with his own prior statement.
You don't want to impeach a victim or a likeable witness. Just refresh recollection instead.