Deposition Preparation Client Guide =================================== Create a deposition preparation guide for client [initials] in [case type] matter. Deposition details: - Client role: [plaintiff/defendant/witness] - Deposition date: [date] - Location: [address] - Opposing counsel: [firm] - Anticipated duration: [hours] - Key topics: [list] DEPOSITION PREPARATION GUIDE WHAT IS A DEPOSITION? [Plain language explanation for client] - Questions under oath - Court reporter present - Can be used at trial - Attorney present but limited objections BEFORE THE DEPOSITION - Review your answers to interrogatories - Review documents you produced - Review your prior statements - Good night sleep - Dress professionally - Arrive 15 minutes early - Eat breakfast DURING THE DEPOSITION — GOLDEN RULES 1. LISTEN TO EVERY QUESTION - Do not answer until question is complete - Ask to repeat if unclear 2. ANSWER ONLY WHAT IS ASKED - Short precise answers - Do not volunteer information - If yes or no suffices — stop there 3. TELL THE TRUTH - You are under oath - It is okay to say you do not know - It is okay to say you do not remember - Do not guess 4. PAUSE BEFORE ANSWERING - Gives attorney time to object - Gives you time to think - Silence is okay 5. STAY CALM - Opposing counsel may be aggressive - Do not get defensive or angry - Speak slowly and clearly FREQUENTLY ASKED QUESTION TYPES - Background questions: [how to handle] - Document questions: [read carefully first] - Prior statement questions: [how to handle] - Hypothetical questions: [object — then answer] AFTER THE DEPOSITION - Do not discuss testimony - Review transcript when received - Note corrections within deadline - Contact attorney with concerns Note: This is general guidance — specific preparation requires attorney consultation Source: https://promptzyo.com/prompt/deposition-preparation-client-guide