Browse Legal Professionals SECTION 4: Litigation Support

The Deposition Preparation Prompt

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The Deposition Preparation Prompt

Prepare a deposition outline.

Deponent's role: [DESCRIBE]
What I need to establish: [LIST OBJECTIVES IN PRIORITY ORDER]
What I expect them to resist: [DESCRIBE]
Documents I will use: [DESCRIBE]
Time available: [HOURS]

Produce:
1. A question outline by topic, in the order I should take them
2. For each objective: the chain of questions that builds to it,
   starting from propositions they cannot dispute
3. Foundation questions for each document
4. Follow-ups for each likely evasive answer
5. The questions I must ask regardless of how it goes
6. Questions NOT to ask — where I would open a door
7. How to lock in an answer before moving on
8. Where to stop on each topic

Write actual questions, short and single-fact. No compound
questions.

Do not cite anything. Do not assume facts I have not given.

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