A deposition you defend is unlikely to make your case but, as many lawyers have learned the hard way, it may very well break your case. An ill-prepared client is your worst enemy. So it is up to the lawyer to make sure that the witness is ready when deposition day arrives. The key to a successful deposition is a successful deposition preparation session.
In order to properly prepare the client, you must prepare yourself first. Understand what the case is about. This means becoming familiar—if you are not already—with both the facts and the law at issue. It also means developing a familiarity with the documents. Depending on the complexity of the case, there may be a sizable amount of documents that have been produced and you need to dive in and find the ones your client may be asked about.
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