DEPOSITION PREPARATION

Let me help lower your clients' stress level by making sure they are prepared.

Deposition preparation is necessary, even when clients appear to be well spoken and you believe they will be fine during their deposition. They need to understand they will be answering questions differently than they would if they were in a regular conversation. For instance, they need to be made aware that silence is fine. One tactic lawyers sometimes use is to sit quietly and stare at the person being deposed to see if they will continue talking. Witnesses should be made aware that they should not continue speaking if there is no question pending. 

Deposition Preparation is also necessary to be sure that clients understand they should not to joke or be facetious in a deposition because when the deposition is transcribed, it does not look like a joke. 

Clients should be made aware of whether or not the deposition will be video recorded because more preparation will be necessary. If the deposition is going to be video recorded, not only will you need to make sure your client dresses appropriately; you will also want to make sure that your client controls any nervous behaviors.  Nervous behaviors such as playing with hair or nervous smiling at inappropriate times may not only be distracting for the viewer, but the behavior may also provide insight for anyone who is familiar with body language. If the deposition will be video recorded, deposition preparation will need to be more in depth to assure the party being deposed is properly prepared.