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How To Prepare For A Deposition

Focus your client on the facts and issues that you know are important. For honing overall deposition skills I recommend two courses.

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Questions may address documents relevant to the issues involved in the deposition.

How to prepare for a deposition. Might the deponent reveal previously unknown factual information give useful ie. I created these seven short videos to prepare my clients for their depositions. Whether you are defending the deposition of a party in a complex case or a percipient witness with limited material knowledge you must take the time to adequately prepare your client for his or her deposition.

To avoid this from happening prepare for your deposition with your attorney beforehand and do not bring documents with you to the deposition. The Ten Essential Steps As a new associate youre likely to be taking depositions. Avoid keeping to outline at the expense of natural flow of events.

Discuss these tips and any questions you. You should be able to shape it according to the situation any time at the deposition when unexpected issues arise. The subject matter of deposition questions often goes way beyond the subject incident itself and can be very broad.

Such questions can be designed to reveal your theory of the case or strategy. Your attorney might also be able to give you a description of the opposing counsel prior outcomes of depositions like yours and other information to ease your nerves. Questions may also focus on conversations the witness.

Preparing a client or witness for deposition should be an important part of a smart attorneys preparation process. How to Prepare for a Deposition. Trenk is a Partner at Trenk DiPasquale Della Fera Sodono PC.

Also be prepared to separate facts from their opinion. More explanation here at. Witnesses should where possible answer such questions generally.

You should have at least one practice session preferably with another attorney. For more depo tips read Preparing Your Client For Deposition in Lit Tip Of The Week. Below is a non-exhaustive list of DOs and DONTs to help you prepare.

You may ask for a 5-minute break any time review your outline and cover the items that were not voiced. DEPoSE or DoNT DEPoSE. Understand the case better and avoid any unpleasant surprises when the witness takes the stand.

Make sure you know and understand the keywords they may use and how to rebut their testimony. Begin the deposition preparation session by reviewing the key facts of the case with your client. Heres a ten-step checklist to help you avoid common pitfalls that can hurt a deposition.

If your attorney is good he or she will prepare you for the deposition. Although it seems obvious many attorneys do not research the law before starting discovery. To properly prepare for a deposition speak with your attorney beforehand to get an idea about the kinds of questions you will be asked when you testify.

Research the law and keep the theory of the case in mind. A deposition gives an opportunity for the parties to understand their weak spots and prepare for ways to rebut them during trial. Learn facts from the witness and preserve them as testimony.

In order to take effective depositions attorneys need to know what questions to ask and to do that they need to know the law. Depending on your clients experience with the discovery process and the purpose of a deposition it may be helpful to go through the procedures well in advance of the scheduled deposition. Trenk outlines the steps to prepare for a deposition.

Have your client recite the key facts of the case to you in chronological order. Is the deposition even necessary. Develop your style by takingdefending depositions or by watch your mentors in court.

So often when there are support issues the best way to prepare is to go through the tax records income records and discuss the different issues that come up during your deposition about income. Finally for property issues its very important to make a list of all of your assets and debts so that you can be prepared to answer questions. The National Institute for Trial Advocacy Deposition Skills Training 17 hours and Robert Musantes Take A Killer Deposition full-day course.

I decided to share my tips with the general public because everyone should know how to give a great deposition. Learn how to take a deposition in corporate law from Spilman Thomas Battle. Prepare Some Basic Questions.

Develop familiarity with the provisions of Rules 27-32 and Rule 45 of the Rules of Civil Procedure. Prepare your client for his or her deposition. Tips to Prepare for a Deposition.

Practice with your attorney. Its also a good idea to review the location. Deposition questions can cover irrelevant topics.

Take effective depositions by spending time preparing. Witness preparation for the deposition itself. There are two main reasons for taking a deposition.

Deposition witnesses with superior knowledge also called expert witnesses will incorporate technical jargon into their testimony so you must be prepared for this.

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