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

by: Prince, Glover & Hayes Thursday, April 29th, 2010


There has been a continuing evolution of the importance of conducting discovery in general, and deposition taking specifically, since I began the practice of law in 1975. Both have morphed into very important tools of representation, not just litigation. This is not so much an observation as it is a blueprint for success. To embody the haphazard, cavalier attitude of the late-seventies attorney concerning deposition taking, is to ensure a poor result for your client. It goes without underscoring that competent defending and taking depositions is dependent on above- average preparation for the deposition event. The outcome of your case, the adequacy of your representation, may indeed be determined by how much or little you prepare for a deposition – from the plaintiff’s or the defendant’s vantage.

I write in an effort to impress on you the importance of approaching the deposition date with a heightened sense of importance. Only then will you adequately prepare for the deposition. Quality thought and planning should precede the deposition. Acting on your plan should be more than “grabbing” the file the night before to assist in preparing your agenda for the deposition. The taking of any deposition should be part of your overall plan of discovery and strategy. It should be timely coordinated with other forms and types of discovery. It should also be coordinated with other depositions you take and have taken.


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