In a recent Daily Journal article, Thompson Coburn partner Michael Kun shared 10 key steps for effectively preparing a witness for deposition. His guidance includes knowing the facts, explaining the purpose and process of the deposition, and thoroughly reviewing critical documents with the witness.
“Few moments in litigation make lawyers as nervous as sending an inadequately prepared witness into a deposition,” Mike wrote. “But an overprepared or rehearsed witness presents its own challenges.”
He emphasized that successful deposition preparation is “neither about coaching testimony nor scripting a witness’s answers.” Instead, it focuses on helping witnesses understand the process, refresh their recollection of relevant topics, appreciate the importance of accuracy, and feel prepared to testify truthfully and confidently.
Read the full article here (registration required).
