The National Institute for Trial Advocacy (NITA) offers a sample chapter from one of its books about depositions: "Preparing to Take the Deposition" (pdf). The chapter contains a lot of useful advice, subdivided into these topics:
- Your Frame of Mind
- Creating the Deposition Outline
- Research the Law
- Identify All Available Facts
- Construct Your Theory of the Case
- Identifying the Opponent's Factual and Legal Theories
- Generating Questions
- Organizing the Deposition Outline
- Using the Outline at the Deposition
- A Final Word About Preparation
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