In a recent post, I mentioned having three meetings with your client before her deposition. Your first meeting, which I refer to as the Reconnaissance meeting, affords you the opportunity to learn everything your client knows about the case and identify and secure all the relevant documents. This initial meeting can be done over the phone. After the introductions and general description of what to expect at deposition, take some time to learn everything your client knows about the case, the parties involved, the documents and any thoughts and opinions she may have about the proceedings. Also, determine the identity and location of all relevant documents and make arrangements to secure copies (originals where appropriate). This initial meeting affords you the opportunity to learn everything your client knows about the case, determine what information is helpful and what information is damaging and helps you begin to evaluate what type of witness your client will make at deposition. Let her know you plan on two additional meetings, the next a few weeks before her deposition and the third a few days before her deposition, both in person. Share this: Twitter LinkedIn Email Digg Reddit StumbleUpon Facebook Like this: Be the first to like this post.
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