Preparing A Witness For A Successful Deposition

Law360, New York (September 8, 2008, 12:00 AM EDT) -- In my 20-some years of working with company witnesses as part of the discovery process, I’ve learned that the prospects of a deposition can stress even the most accomplished corporate executive.

One way of lowering their level of anxiety is to give them mileposts to follow as they prepare. Something that’s easy to remember but useful. This article shares with counsel my system for witness preparation, with tips and tricks for a successful undertaking.

My approach is based on a simple acronym – PLEASE.

It goes...
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