Preparing Your Client for Deposition – Part 1

The most important deposition in any case is your client's deposition. An aberrant admission can serve up a summary judgment to the other side or cost you dearly at trial. Therefore the most important thing you can do in any case is properly prepare your client for deposition. Over preparation is the key. I suggest three meetings, which I will call (1) Reconnaissance; (2) Preparation and Indoctrination; and (3) Cross-Examination. I will discuss these meetings in greater detail in upcoming posts, but for now, let me provide you a general overview. The first meeting is a get-to-know you meeting with the client, where you learn everything he knows and secure all relevant documents. The second meeting is the initial preparation for the deposition, a how-to for depositions, and a review of all the relevant materials with the client. The third meeting is a dry run of the cross-examination he will endure. If after his deposition your client tells you that the opposing party's cross-examination was a cake walk compared to your mock cross-examination, then you've done your job. The most important part of preparing your client is appreciating that it will take time and should be begun well before his deposition date. Share this: Twitter LinkedIn Email Digg Reddit StumbleUpon Facebook Like this: Be the first to like this post.

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