Deposition Preparation: The Four Simple Rules

Edna Selan Epstein
If your client has never given a deposition, before you do anything else, explain what the purpose of the deposition is.

If your client has never given a deposition, before you do anything else, explain what the purpose of the deposition is.

Shutterstock

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.

Premium Content For:
  • Current ABA Member
Join - Now