Preparing Yourself to Conduct or Defend a Deposition

Ohio State Bar Association

On November 6, Tom presented to the OSBA on deposition preparation, stressing how preparation is indispensable to success in litigation. Also emphasizing the need for hard work, or “boiler room labor”, Tom focused on the importance of performing fundamentals well every time and presenting skillfully. He broke down, step by step, what goes into taking a deposition, from managing the expectations of a client to preparing the client to be a witness. Tom also talked about acquiring and organizing evidence, creating an overall plan for questioning, and the need to write each question out in detail.