How to prepare a deposition: A guide for divorce attorneys and clients

How to Prepare for a Discovery Deposition

  1. To protect the deposition from possible objections later on, and
  2. To allow the attorney taking the deposition to establish a rapport with the deponent. The attorney taking the deposition wants to establish a rapport with the deponent so that the deponent will let their guard down and provide information that would normally not be provided.

Do a Mock Deposition

Other Helpful Tips in Preparing for a Deposition

  1. Pause before answering a question.
  2. Only answer questions that you understand and if you do not understand, ask for clarification.
  3. Never guess
  4. Never speak in absolutes (“never,” “always”).
  5. Stay calm.
  6. You can ask for a break.
  7. Conversations with your attorney are confidential.



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