Like all professionals, we lawyers often speak our own special language. We forget that laypeople do not understand the lingo that has become second nature to us.
So, when preparing a client for a deposition—even a fairly sophisticated client who you have reason to believe understands lawyer talk—act as if your client is a naïf. If you do it well, even the most sophisticated client will be grateful and will not feel condescended to or insulted.
First and foremost, don’t assume your client even knows what a deposition is. Be sure to ask whether your client has ever given a deposition and, if so, ask for feedback:
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