Articles and Blog Posts
Proper Deposition Objections
Whether you are defending (or taking) your first or your hundredth deposition, you must be ready to handle objections. That means knowing which objections are proper and which are not. Once you know, you can keep the deposition proceeding smoothly — and avoid embarrassing yourself.
Deposition Preparation for the Witness
Carol Ann Wilson has over 30+ years of experience working for lawyers, and developed this compilation of advice given by various attorneys that would be easily understood by the typical lay witness.
Preparing a Witness for a Successful Deposition
Preparing your client to testify at deposition can make or break a lawsuit. Defending your client’s deposition can be a nerve-wracking, sweaty armpit experience.At the end of the day, a weak performance or just one poor answer can sink a case. But even with stakes this high, most lawyers do not spend enough time preparing the client to testify. While the demands of your practice, your client’s calendar, or the legal budget for the case may not allow it, ideally you should spend at least two hours of preparation with the client for each anticipated hour of deposition. And sending your client home with a stack of documents to review is no substitute for the face-to-face prep session.
Preparing Your Client for Deposition
Whether representing a plaintiff or a defendant, we all know that our client's deposition is a defensive exercise. Thus, in preparing clients for depositions, we explain the usual cautionary procedural guidelines: Say as little as possible, answer only what is asked, and don't volunteer information. Our goal is to have a deposition record that to the extent possible will not contradict the theory of the case we seek to prove at trial.
Preparing Your Witness for Deposition and Trial
This article focuses on strategies and tactics for preparing your witness for deposition or trial testimony, and will also address relevant portions of the Texas Rules of Civil Procedure and the Texas Rules of Disciplinary Procedure, as necessary, to fully develop the discussion.
Making Your Client a Stellar Witness: A Step by Step Guide to Deposition Witness Preparation
Preparing witnesses for deposition has been a calling for decades over hundreds of trials and thousands of witnesses. I know that after absorbing the following ten steps that you will be better at preparing witnesses, even if you have prepared hundreds of clients. Further, your clients will be the best possible witnesses they can be deposition. And who does not deserve that?