Taking and Defending Effective Depositions - How to Prepare
Colin E. Kaufman
June 25, 2008
Deposition Preparation- Trial is where the fun is; depositions are where the work gets done. Deposition comes near the end (unless it rekindles discovery) – it should not be “discovery” in the sense of finding out new things - you should know what the case is about well before depositions.
You should have at least the following papers included in the file in two different categories:
1. Judicially obtained:
i. All the records dealing with the incident or course of events, aftermath & damages
ii. Photos
iii. Recordings
iv. Tangible items (e.g. exemplars of equipment)
v. Expert Information (in federal – reports)
vi. Bill of Particulars
vii. Responses to Interrogatories
2. Extra-Judicial:
i. Background on the witness
ii. Interviews of those who know the witness
iii. Interview of the non-party witness
iv. Criminal record (where appropriate)
v. Time line
