Ten Tips for Preparing Witnesses for Deposition

The American Bar Association
Young Lawyers Section
Offers to its members these

Ten Tips for Preparing Witnesses for Deposition

1. Encourage the witness to tell the truth.

2. Develop a trusting relationship with your witness.

3. Understand the case themes.

4. Explain How to Answer Questions About Documents.

5. Recognize your witness’ strengths and weaknesses.

6. Instruct the witness not to volunteer information.

7. Tell the witness to expect questions about preparation.

8. Listen and Practice.

9. Explain objections.

10. Last but not least, be prepared.

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