A party's sworn interrogatory answers often predate the party's deposition by weeks or months, which is probably why some lawyers forget to review them with the witness as part of their standard deposition preparation.
Though surprising, it happens all the time, not only to overworked plaintiff lawyers but also to defense lawyers who forget that one of the defendant's employees had to verify the interrogatory answers.
It's a mistake that can lead to some terrible testimony, so be sure to add this reminder to your checklist: have the witness review his prior interrogatory answers before the deposition begins.
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