Page 78 - FDCC Deposition Drills

Deposition Drills How to Teach Deposition Skills
Preparing Deposition Materials for the Client
Typically, one prepares a binder or sends an e-mail with attachments to the client with all the documents she needs to prepare for her deposition. Deciding what to send the client is both anartandascience. Youwanttosendtheclienteverythingsheneedsbutyoudon’twantto bury her in paper and overwhelm her. This exercise addresses what to send to the client for her deposition.
EXPLANATION
Participants learn what documents to select and gather to provide the client for her deposition.
EXERCISE
Think through a document intensive case wherein you provided your client lots of documents in preparing her for her deposition. Describe the case to the participants and askthemwhatdocumentstheybelieveshouldbeprovidedtotheclientandwhy. Discuss with the participants the types of documents you can provide a client and why you should (or should not) provide those documents to the client. Also discuss how to organize and present documents to a client.
LESSONS LEARNED
This exercise teaches participants to think about what documents exist in a case, which of those to provide to the client and how best to present those documents to the client.
A FEW QUESTIONS TO DISCUSS
What are the relevant documents in a given case?
What documents should you provide the client to prepare for her deposition? What documents shouldn’t you provide her?
How should you organize and present documents to the client?
Should you create charts, lists or chronologies for the client?
SECTION 06 DEFENDING DEPOSITIONS
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