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You’ve taken the deposition – now what?
Now that you have completed the deposition, prepare a summary as soon as possible.  The summary should include your general impressions of the witness, how they appeared at the deposition, a summary of their educational background and experience, highlights from the deposition testimony, and how the testimony affects the theories of the case.  Unless you prepare the summary within a few days, the details quickly leave your memory.

If the witness provided information that may be helpful in discovery, do not let the leads get cold. Send out subpoenas, additional written discovery, or additional deposition notices. Call your investigator and/or client.  If you wait, you may not reach potential witnesses before opposing counsel des.

Finally, keep the whole experience in perspective. There is an art to taking a good deposition, and practice makes perfect in all forms of art. Whatever techniques and steps you employ before, during and after a deposition, remember that you are at your most effective when you are yourself rather than a imitation of another lawyer’s style or personality.