Pre-Deposition Tips: How to Prepare to Take a Deposition- Plaintiff’s Perspective

by: Prince, Glover & Hayes Friday, May 7th, 2010

Steps of Preperation:

To really be ready to take a deposition, you need to know four things: the lawyer, the deponent, the subject matter and the rules.

The Lawyer

With the advent of listservs and the internet, it is easy to find out information on opposing counsel. Some opposing lawyers require more patience than others, and some may require you to brush up on the Rules of Civil Procedure that apply to discovery in general and depositions specifically.

The Deponent

Again, if you don’t know anything about the deponent, ask around or do a little research on the internet. “Googling” someone can provide valuable information on news articles in which they appeared, articles or books they have written, or maybe some other information that you can use in your questioning. If burglars can use the net to find out about your vacations and trips, surely we can use it as a tool to help us prepare for depositions!


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