Before you serve a deposition notice, make sure your timing complies with the statutes.
When preparing your client for his or her deposition, devote particular attention to explaining the following objectionable areas of inquiry and substantive law on those areas.
The first thing to do in preparing for a deposition is to think about your goal—what are you trying to achieve with this particular deposition? Your goal should be reflected in your conduct toward the deponent and the scope of your questions. Here’s a look at how three common deposition goals should play out.