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September 16, 2005



I have a friend who recently took up woodworking as a hobby. The projects often involve the use of equipment such as the tablesaw that can easily inflict some pretty serious damage to the careless or unwary. My freond has told me that there are two groups most likely to sustain a woodworking injury. He says that the first, unsurprisingly, are the neophytes. The second are those with substantial experience. According to the standard woodworking wisdom, the experienced can become complacent and overconfident through in their familiarity with the procedures. I have heard a similar phenomena exists in shooting and hunting.
I believe a healthy respect for the process, whether it be depositions, woodworking or shooting can be most useful. Failure to prepare for a deposition can lead to real consequences for your case and wastes your client's resources and the time of the witness. This is true both taking and defending.
Every case has issues that the experienced litigator must worry about and one should have the issues, the story, and what you need for trial and summary judgment whenever one preps in order to avoid your case suffering injury (I have found that experience has, if anything, raised my anxiety in the preparation phase of depositions, though prep and experience have lowered my aniety once the deposition has started.)

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