Preparing Witnesses for Depositions: Here's a Step That's Often Forgotten

Neglecting to have a client review his or her prior interrogatory responses is an especially common deposition-preparation error. Without this review, consistency in the client's sworn responses becomes difficult to achieve, especially when the facts of the case are complex or the passing of time is causing memories to fade.   

When preparing witnesses for depositions, make sure they review all their prior sworn responses, including past testimony, affidavits, and interrogatory answers.