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Review the operative pleadings, discovery and law and motion
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Review the operative pleadings and law and motion. There are various documents in your firm's files containing helpful information, including: the complaint, answer, law and motion matters, written discovery responses, and possibly investigative or background reports. Be familiar with these documents and how your opponent's facts and contentions fit your view of the case's issues. Identify documents from which you wish to question the witness and make copies for each attorney, the court reporter, and the witness.

On the day of the deposition, your focus should be on your outline, not on last-minute copying, so stay later the night before and finish preparing. Also, there are terms of art used in depositions. Check with other attorneys and obtain your firm's version of opening admonitions and closing stipulation.

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