This article identifies tips for taking depositions. The two most important tips: Get organized, and keep it simple. That said, let's dive into greater detail.
Start by Identifying What You Want to Accomplish
It is a good practice to start your deposition preparation by making a list of the things you want to get from the witness in the deposition. As a starting point, we make a list of the five most important things we need to get the witness to admit or concede during the deposition. The list can be expanded or contracted as necessary depending on the facts and complexity of the case. The list serves as the basis for a deposition outline.