For many lawyers, a how-to article about deposition designations is about as exciting as rearranging a sock drawer. But, that’s the problem.

In so many trials, attorneys relegate the task of selecting deposition excerpts to the last minute and to the lowliest associate on the team — what a wasted opportunity. In almost every case, testimony from an unavailable witness will be important, sometimes critical. Treat that testimony with the same type of care and preparation as live testimony. Doing so requires planning ahead.