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If it’s your first one make a cheat sheet of proper objections and don’t be afraid to ask for a recess if your client looks tired or is getting off track. You can always take them to a different room to talk it out and try to get them back on track with their responses. Also reassure your client that they should ask the deposing attorney to clarify their question if it’s not completely clear to them. Also many attorneys will throw a document at the witness and start asking questions right away so you should make sure your witness has time to read the document before they answer any questions or you can ask the other attorney if they want your witness to focus on a specific area of the document if it’s large.
Don’t forget to make objections! Take breaks if you feel like you need to guide your client / they seem like they’re getting tired. Make sure your client is prepped!
Do have a cheat sheet of objections but don’t over object. Make a clear outline of what issues you will die on the cross for (privilege only). Otherwise remember to make your objections but know that your client can still be instructed to answer.
Also don’t be afraid to go off record if your client gets flustered. Take a break, talk and have them collect themselves and then resume.
Zoom or in person?
The hardest thing I’ve found about zoom is finding the best way to communicate effectively with your client. It’s so much more difficult to read the room. I suggest setting up a way to communicate with your client if they need a break, etc. and then how you can discuss after. In matrimonial cases in particular, emotions can run high so I find it very helpful to give clients a plan.
In addition to the other comments, I suggest doing really thorough prep with the client. Run through the logistics with them, talk about decorum and remind them not to have anyone else present (especially their kids if it’s custody!) Anticipate what the other side will ask and run through those specific questions with your client. I suggest to clients they rely on 5 answers: yes, no, yes and no, I don’t know and I don’t recall - then elaborate. I also tell clients to wait a second or two before answering - they can gather their thoughts and you can object with a clean record. When you go through the prep, it’ll give you a good outline of where your objections will fall and help you anticipate when to make them.
At the end of the day and no matter how much you prepare your client, they’ll inevitably do something totally off script so don’t let it fluster you. Take a break, give them a kick and do your best to keep them on track.
When you’re defending, keep in mind how the transcript will look when and if you later argue in court. Decide in advance if there is anything that requires significant argument or concluding the deposition, otherwise preserve your objections and keep them succinct.
Good luck!