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Call the client for information about the deponent
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Call your client before the deposition. Since clients have a tendency to share information on a need-to-know basis, you will want to contact your client for his or her point of view. In discussing a witness's role in the case with your client, you may uncover additional issues in need of attention. At the very least, the client will appreciate the call.
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MSD@LACBA.ORG
