Page 77 - FDCC Deposition Drills

Deposition Drills How to Teach Deposition Skills
Preparing a Client for Deposition
Preparing a client for deposition is a critical skill to ensure your client provides the best testimony possible. Different attorneys have different approaches to preparing clients for deposition. Exposing your attorneys to various approaches helps them consider which is the best approach for a given client in a given case.
EXPLANATION
Participants learn how to prepare a client for deposition.
EXERCISE
Lead a discussion about client preparation. Explain how you prepare a client for deposition, and your different approaches to different cases and different clients. Encourage participants to ask questions about concerns, issues and thoughts they have about preparing clients for depositions.
LESSONS LEARNED
The big takeaway is that the client’s deposition is crucial and that you must spend as much time and energy as necessary to ensure the client performs optimally at deposition. That means deposition preparations may extend over several days to ensure the client knows what to expect, what questions she’ll be asked and how best to answer them.
A FEW QUESTIONS TO DISCUSS
Why is the client’s Deposition the most important deposition in the case?
What are different approaches to preparing a client for deposition?
How do you handle a client who doesn’t want to spend the time preparing? How do you handle a client who isn’t being cooperative during deposition prep?
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SECTION 06 DEFENDING DEPOSITIONS