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

by: Prince, Glover & Hayes Thursday, May 13th, 2010


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 Subject Matter

For any deposition, include most, or all, of the following steps of preparation concerning the deposition and its subject matter:

(1) Prepare an outline of topics to cover
(2) Consult the following sources to complete your outline search:
a. the file(s) looking at
1. statements
2. pleadings
3. disclosures
4. any other key information
b. important documents
c. other depositions
d. other paper discovery
e. photographs
f. other lawyers – both in and out of your firm
g. your experts
h. your client
i. the scene, the product, the writing
j. the law – Rule 30; jury instructions; Rule 23
k. the internet:
1. alacourt, Pacer
3. Google
4. Myspace, Facebook, You-Tube

Your outline preparation should be completed with several considerations in mind; (a) your purpose in taking it (b) discovering the good, bad and ugly (c) if and when to do a direct or cross during the examination (d) the type of deposition (e) what rules you need to know.


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