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By having a plan and trusting your instincts, you can make your first deposition a success. As an associate, you have the opportunity to observe depositions at your firm. When your turn comes to take one, you may feel slightly nervous and in need of some organization. The steps that you take as you prepare for the deposition can ensure that you make your mark.
Top Ten Checklist
arrow.gif What is the theory of your case?
Review the operative pleadings, discovery and law and motion.
Create your outline for deposition
Call the client for information about the deponent.
Remember: this is YOUR deposition, not opposing counsel's.
Questions: general to the specific
Dealing with ornery witnesses.
Handling testy opposing counsel
Halting the deposition
You’ve taken the deposition – now what?



Author: Margaret P. Stevens
Margaret P. Stevens, Esq. Practices general civil litigation with Liner Yankelevitz Sunshine & Regenstreif LLP and is a former president of LACBA Barristers.