June 01, 2018 Sidebar

How to Prep a Witness for a Deposition

Deposition disasters happen, but here's a checklist that can help the odds.

Kenneth P. Nolan | The author, a senior editor of Litigation and the author of A Streetwise Guide to Litigation (ABA 2013), is counsel to Speiser Krause, Rye Brook, New York.

Download a printable PDF of this article.

I was young and excited. I was finally handling a deposition on my own. A law school pal referred her cousin who was injured at Kennedy Airport when he drove a vehicle into the wing of a giant 727. Of course I took the case. I told you I was young. The theory was that the lights from the terminal were so blinding that my schlub couldn’t see the wing on the Boeing jet and ran into it, nearly slicing off his head. The engines on the 727s were mounted to the tail, so the wing had no definition, which was equivalent in my somewhat delusional rendition to a thin knife that my guy forgot to notice in one of the busiest airports in the world. Yeah, I was really young.

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