Arizona Sample Letter to Client - Deposition of Client Scheduled
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How to fill out Sample Letter To Client - Deposition Of Client Scheduled?
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FAQ
23. As a reminder, the Federal Rules allow an instruction not to answer ?only when necessary to preserve a privilege, to enforce a limitation ordered by the court, or to present a motion [for a protective order] under Rule 30(d)(3).? See Fed. R.
Deposition Tips Be prepared. ... Think before answering. ... Never volunteer information. ... Make sure you understand the question. ... You must tell the truth. ... Don't get rattled or upset. ... Don't guess. ... If you do not remember, say so.
Go over where and when the deposition will take place, who will be present and why, and the role of the court reporter and the videographer (if the deposition will be videotaped). Also, explain the oath. Explain what a deposition is. Describe what a deposition is so that your client is familiar with the basic process.
The most basic preparation should include advising the witness to tell the truth; understand the question posed; answer the question posed and no more; remain calm and civil; if the witness does not know an answer, say so, without guessing or speculation; and let the attorney do his or her job objecting and arguing ...
Brief and concise answers are best. If you don't know the answer, ?I don't know? is a perfectly good answer. Don't guess, speculate, or play a hunch. A deposition is sworn testimony; only say what you know to be true.
Deposition DON'Ts: Guess or speculate. ?I don't know? or ?I can't remember? is acceptable. Be anxious or stressed out. It will affect what you say and how you appear. Be defensive or angry. Never argue with the attorney. Offer information not requested. ... Talk too much or ramble. ... Talk too little. ... Be too extreme.
Know the case facts and law. You must have a working knowledge of the facts and a strong handle on the law to be able to anticipate the questions that will be asked. If you can anticipate Page 2 the questions, you will be in the best position to lodge appropriate objections and to prepare your witness properly.
