Shoes polished. Suit pressed. Briefcase monogrammed. It’s Day One of being a lawyer. Then the partner pops into your office and says, “Here is a file. Go depose the opposing party.” Say again? Deposing wasn’t on the bar exam! Now what? Adopt this mindset: Ignorance is always curable. In that spirit, here is “A Starter’s Kit to Deposing” in the form of questions that are commonly asked but seldom answered.

Question No. 1: Who should I have with me at the deposition?

This is an interesting strategic call for the corporate defendant. Federal law allows more than one corporate rep. So say you are defending a whistleblower lawsuit: you can have both the in-house counsel as well as the manager accused of making the decision to fire the plaintiff. Take a copy of In re Terra International, 134 F. 3d 302 (5th Cir. 1998), with you to the deposition. Solid support.

Question No. 2: How do I leverage the presence of the corporate reps (Part 1)?