Any advice on deposition preparation for a corporate designee? What are things to keep in mind that differ from fact witness preparation? Thanks!

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I think the best place to start is looking at what causes of action are being alleged against this corporation and the theories of liability for same. Then look at the elements for them, the purpose of the other side in deposing your client should be to get info to meet or disprove these same elements. From there you prep your client to either answer or refute the satisfaction of these elements and you can branch out from there.

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Thanks!

You need to practice with the witness so he or she learns to only answer the question asked and learns to stop guessing. For example, if someone asks "Do you have a watch?" You don't need your witness to say "Yes it's 2:15". Takes practice because depositions are not like casual conversations. GL.

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Don’t be bullied into a yes or no answer. “It depends” is a perfectly fine answer.

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Provide only factual evidence and keep feelings out of any answers.

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Listen carefully...very carefully...to even the simplest of questions, then formulate your answer and reply. No matter the tone of plaintiff counsel or their attempt to unnerve you by asking multiple questions in different ways that yield the same answer...do not get taken off your game. Take a 5-10 minute break every 60-75 minutes. Good luck!

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Was there a notice of topics filed w the court? If so make sure you go through it w your corp rep! You got this!

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