March 2017Volume 18Number 3PDF icon PDF version (for best printing)

In-sites: Deposition tips

For many lawyers, we do the things the way we have always done them. Once you establish a routine, you stick to it.

To break that cycle – and acknowledge that there might be some new tricks to learn – here are some great articles and blogs on taking depositions and preparing witnesses for depositions. You can always learn something new!

The Illinois Trial Practice (http://www.illinoistrialpractice.com/depositions/) had two great articles by Evan Schaeffer. One, “How to Take Depositions Like a Pro,” provides practical tips for taking depositions. <https://lawyerist.com/82652/take-deposition-like-pro/>. There’s a bonus article by Schaeffer entitled “How to Have a Collegial Relationship with Opposing Counsel.” https://lawyerist.com/80589/collegial-relationship-opposing-counsel/ We could all be reminded that we are professionals – and sometimes when we model that behavior, we receive it!

What’s great about the Philly Law Blog is the brass tacks tone and the entertaining video clips. “How to Defend a Deposition – Don’t Just Show Up and Play Lawyer” provides tips and clips. <https://phillylawblog.wordpress.com/2013/04/16/how-to-defend-a-deposition/>.

The use of paper at depositions can be daunting, especially as the hours roll by. The CEBblog has four tips for using exhibits at deposition. <https://blog.ceb.com/2017/02/01/4-tips-for-handling-exhibits-at-deposition/>. Basic? Yes. Worth the reminder? Absolutely.

Most of the tips above are from lawyers. But who better than the court reporter to give attorneys some suggestions after sitting through thousands of depositions? “Lights! Camera! Tips! Preparing your witness for deposition” is an article found in the blog of a court reporting agency about video depositions, ever more popular these days. <http://www.benchmark-reporting.com/blog/lights-camera-tips-preparing-your-witness-for-deposition/>. More advice on video depositions can be attained from the ABA. <http://www.americanbar.org/groups/departments_offices/legal_technology_resources/resources/articles/youraba0410.html>.

A Tulsa law firm’s blog has great suggestions to use when preparing deposition witnesses. Attorneys sometimes forget that this whole experience is foreign to a never-before-deposed witness. Break it down for them using these helpful hints. <http://a-vlaw.com/blog/posts/view/34/tips-for-handling-your-upcoming-deposition>.

As you can see, there are many blogs and articles out there – we found many on preparing for specific types of depositions or witnesses. Remember, you can always learn a new trick!

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