Preparing for your first deposition can be a daunting task for a young new attorney. It has been a year since I took and passed the bar, so naturally more opportunities and responsibilities are presenting themselves, with which I could not be more thrilled. One of these new opportunities and responsibilities is taking depositions. I just recently began conducting and taking my own depositions and it has become abundantly clear that the most important aspect of conducting a deposition is being prepared beforehand. In this article I would like to share some tips with my fellow young attorneys regarding preparation for depositions.

I believe it is paramount that before you begin preparing for and conducting your own depositions that you observe those conducted by an experienced attorney. Luckily, I had the opportunity to observe such an attorney, Alexis Handrich, who has been practicing workers’ compensation law for over a decade. She also shared her preparation techniques, which formed the basis for how I prepare. Having a mentor and someone to help with your preparation can be invaluable and help avoid common mistakes. Watching her depositions also helped me focus on key areas in my preparation, such as identifying when an objection might be made, knowing how to respond when one is made, or determining when you should go off the record to discuss an issue. After watching another experienced attorney prepare and conduct depositions, it will be time to start conducting your own.

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