Preparing Your Client for a Deposition: Dos and Don’ts

The deposition can make a big difference in the outcome of a case. Failing to prepare your client for deposition can have serious consequences. Therefore, it is crucial to take the time necessary to assist your clients. Prior to the deposition, meet with your client for a preparation session. In this article, we’ve put together a basic list of dos and don’ts to help you prepare your clients for their depositions.



1.Explain to your client the procedures for conducting the deposition
2. Instruct your client to dress appropriately
3. Explain the oath
4.Tell the client what the opposing counsel’s role will be in the deposition. Explain admonitions
5. Explain the role of the court reporter and the videographer
6. Prepare a list of mock Q&A for your client(Focus on the facts and issues that you know are important for a case)
7. Emphasize to your client how crucial it is to
● Remain calm and respectful
● Tell the truth
● Only answer the question that is asked.
● Be consistent and avoid traps
8. Tell your client to listen to the questions carefully before answering
9. Tell your client to review any exhibits or documents
10. Instruct your client to avoid off-the-record conversations
11. Explain to your client the attorney-client privilege and the right to speak with you privately during the deposition



Tell your client:

1. Don’t be late
2. Don’t volunteer information
3. Don’t try to explain or justify your answer
4. Don’t help the opposing counsel
5. Don’t argue with the attorney
6. Don’t prepare notes. You cannot use any notes to assist you during your deposition
7. Don’t try to guess or speculate when you do not know the answer
8. Don’t give long, unclear answers
9. Don’t agree to provide documents without consulting with me(your attorney)
10. Don’t give an opinion unless asked


Are You a Deposition Attorney? Here’s what AppearMe Offers You

AppearMe is a web & mobile application that helps attorneys and law firms find litigation support faster and easier than ever before. The application works on a real-time and on-demand basis, enabling you to find a reliable attorney within 60 seconds to protect your client’s rights during the deposition.

Sign up for AppearMe today to have access to a nationwide network of appearance, deposition, and freelance attorneys. Visit our website or download the application from the App Store/Google Play to sign up. 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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