Deposition Instructions To Client
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How to fill out Letter To Client - Deposition Of Client Scheduled?
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FAQ
What Should You Not Say During a Deposition? Guessing or Speculating on Things. ... Saying Things Out of Anger. ... Rambling. ... Speaking in Absolutes. ... Stick to the Facts. ... Take Your Time When Answering Questions. ... Use ?Yes? or ?No? Answers Whenever Possible. ... Get Through Each Question on Its Own.
At this point, the court reporter will administer an oath to the deponent. After that, you can dig into your outline with the standard opening question, "Please state your name for the record," or, if you want to sound like an old pro, "Tell us your name, please."
Guessing or Speculating on Things It is in your best interest to stick to the facts at hand. If you are unsure about the answer to a question, you can always respond, ?I do not know,? or, ?I cannot answer that.? Both of these responses are acceptable and help you avoid guessing or speculating on things.
The key to effectively preparing and presenting a cli- ent for a deposition is to know the case. You must review the pleadings, the discovery responses of all parties, all records relevant to the claim or defense the deponent is expected to testify about, and the relevant case law.
?Once the deposition has begun, the preparation period is over.??28 Counsel should, therefore, refrain from speaking with his or her client during the deposition about the testimony, unless the attorney is prepared for the disclosure of that communication.
