First, and most importantly, your major role is preparing your witness. 99% of defending a deposition properly is the preparation. If you prepare your witness properly, you should be able to just be a potted plant . . . . So how do you do that?
This quote is from the middle of the post, which includes a lot of basic information about defending depositions, including some advice for preparing a client for a deposition.
Here's information about the book from the James Publishing website--
Creating an outline is the most efficient way of formalizing your preparation for a deposition.
Use the outlines and pattern questions in Deposition Checklists & Strategies to avoid omissions, improve your advocacy, and handle unfamiliar areas with confidence.
Underlying law. Each chapter begins with a summary of the substantive law at issue. Also included is an analysis of common defenses.
Deposition outlines. Each chapter contains several full-length deposition Q&A sections organized by issue, based on common fact patterns, and directed at specialized deponents like experts, corporate representatives, and treating physicians. The book’s questions are easy to mix and match with your own.
Commentary. Thorny or common issues are annotated with practice-proven alternatives and solutions.
Bonus outlines. Thumbnail checklists that contain themes and issues rather than question-and answer dialogue are provided for less-common deponents.
Related discovery forms. Complaints, interrogatories, requests for admissions, requests to produce, and more finish each chapter.
Practice tips. Sprinkled through each pattern deposition is practical advice learned from hundreds of depositions.
The book also contains pages of strategies for expert depositions, illustrated by outlines in a variety of types of cases.
If you're interested in honing your deposition skills, please take a look at my book--and thanks!
Digging through an old file on a settled case, I came across some notes that I made during a deposition I was defending. It was a simple hit in the rear auto case and I jotted down some of the questions the defense lawyer asked.
Each question, it seemed, was more wretched than the next. None were spoken in plain English.
Read the full post for some (humorous, at least to me) examples. As Turkewitz observes, "It isn’t really hard to abuse the English language. All you need to do is go to law school."
On April 11, Jim Dedman, in a post at NC Law Blog, described how iPads might be used to do away with paper exhibits at depositions. He concluded, "Someday, though, someday, we’ll be able to arrive at the deposition with just our laptop or tablet . . . But, alas, that day has not yet arrived."
Just two days later, Jeff Richardson at iPhone J.D. brought news of this very development:
I took a deposition yesterday in which the witness had produced thousands of pages of documents. In the past, that would have meant lugging tons lots of boxes and binders to the deposition. Instead, I just put everything on my iPad. I used Apple's Numbers app to read some Excel files. The PDF files went in to my Dropbox account, and while it took over an hour to sync almost 2 GB of data to GoodReader, everything worked great once it was there. Searching for a term in a 2900 page PDF file was slower in GoodReader than it would have been with a laptop computer, but it was fast enough for what I needed during the deposition. It worked great, and reminded me (once again) of why the iPad is such a great litigation tool.
Read both posts in full for more good ideas about the use of iPads at depositions.
The new revision contains a number of new practice tips, a section listing practice tips by type and category, a long appendix featuring real-life deposition transcripts for study, and much more.
Here's a testimonial about the book from Ross Mann, an attorney whom I don't know, yet who was kind enough to email me last month about my book--
Your deposition book was INSTRUMENTAL in my first deposition. I proceeded to take my first adverse dep without ever having seen a dep in my life--and I had full confidence because I thoroughly studied your book. Thanks so much for the work!
You can view and print a detailed brochure about Deposition Checklists and Strategiesat this link (pdf).