Preparing A Witness For Their Deposition

One of the most important factors in helping a lawyer to negotiate a settlement or prepare for trial is how their client completed their deposition. A client that gives a great deposition and clearly explains the facts of the case can sometimes force the other side into negotiating a settlement to avoid a trial. There are several key pieces of information every attorney should discuss with their client before a deposition.

1. The client must be prepared for their deposition. It is the attorney’s job to make sure they are prepared by meeting and discussing the case prior to the deposition. It is recommended that this meeting takes place several days before the scheduled deposition so that it is not rushed. A client that is well prepared by a well prepared attorney will know the answer to almost all of the questions opposing counsel may ask.
2. The client must be relaxed and try to avoid becoming upset or flustered during the deposition. When a client becomes upset during a deposition they may answer incorrectly or provide extraneous information that is not relevant to the case.
3. Attorneys should tell their clients that less is more during a deposition. The client should not expand on their answers when a simple yes or no will do. The client can cause themselves more harm than good sometimes when providing unnecessary details.

http://www.newyorkinjurycasesblog.com/2009/02/articles/faqs-depositions/what-is-a-deposition-and-how-do-i-prepare-for-mine/