How to Prepare Your Client for Deposition

The deposition is one of the key parts of the discovery process that could affect the outcome of a case in various ways. That’s why it is important to prepare your client for a deposition in advance. Start the preparation by explaining to your client the whole process & procedures of deposition, including what to wear, what to bring(what not to bring), what time to arrive, who will be present and why, how the deposition starts, and when to begin answering questions. Also, don’t forget to explain the oath. Remember, the more time you take to prepare your client the more smoothly the deposition will go. The following advice and suggestions will help you while preparing your client for the deposition. 

  • The first rule – tell the truth. Remind your clients of the basic rules for answering questions under oath.
  • Help your client deal with anxiety and fear. If your client has never testified at a deposition, it could be an intimidating experience. 
  • Review all the relevant documents with your client, including all prior statements of your client.
  • Ask your client every imaginable question that you anticipate he or she will be asked by the opposing side at a deposition.
  • Tell your client to listen carefully to the questions that are being asked before answering.
  • Instruct your client: ‘’If you don’t know the answer to a question, say so without trying to guess.’’
  • Remind your client to think before speaking, avoid using slang and profanity. The court reporter will make a word-for-word transcription of everything said during the deposition. 
  • Be consistent and avoid traps. Highlight to your client about the importance of being consistent in his/her answers. The opposing attorney may try to ask the same question in several different ways.
  • Instruct your client to stay out of arguments between the attorneys, remain calm and respectful at all times, regardless of any provocation by the opposing attorney. 
  • Explain to your client to take breaks as necessary. 


Looking for an Attorney to Cover Your Deposition?

AppearMe is a mobile & web application that helps attorneys and law firms to find deposition attorneys anywhere in the country. Our real-time and on-demand nationwide network of deposition attorneys enables you to find a local deposition attorney in a matter of seconds. To explore AppearMe, download the free application from the App Store/Google Play or visit our website and create your free account. It takes only 3-4 minutes to sign up and submit a request, and 60 seconds on average to find a deposition attorney in your city.

Please contact us if you have questions or need help by calling at (888) 900-3080 or sending an email to [email protected].


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