Taking my first deposition tomorrow. It’s of a nonparty. Any tips? Obviously I have a hard time with focus and organization. Any tips on preparing, taking, and objecting would be great.

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Wishes and prayers you get someone that uses an actual computer if it’s remote, and who knows how to mute/turn their screen off.

I had to ask someone to put their phone down so sue wouldn’t take the depo with her to the bathroom. So, good luck!

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Practice! You can find friends or family to "volunteer."

I write out every question I want to ask, and then include supporting details underneath, references to specific documents to pull out if the deponent deviates from the expected answer, etc. After that, I try to divide the questions into sections, although there will always be some miscellaneous ones. Here’s an example:

What did you tell Dr. Johnson about your fall?
- on 6/7/20, plaintiff told Dr. Johnson she fell on her right side
- *contradicts incident report where she stated she fell on her left side.

And then I would have those medical records and the incident report in a binder, and it’s up to you to decide whether to press on any inconsistencies

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Read and go about your materials several times. Or you can listen to calm music minutes before your taking of the deposition.

OP: how did it go?

Organize your topics by trigger words— short list of one word things that can get you back on track if you get lost midstream

Hello, OP! I just read this post. It's probably too late to give tips. Just here to ask how did it go?

Opposing counsel was “sick” and didn’t have a replacement attorney so we’ve rescheduled for mid January

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