5.9 Tips for Working with Clients

LibraryCivil Discovery in Virginia (Virginia CLE) (2021 Ed.)

5.9 TIPS FOR WORKING WITH CLIENTS

1. Experience breeds both confidence as well as hubris. Discuss with your client whether he or she has ever had their deposition taken before and in what circumstances. Then explain what a deposition in this case, this situation and these circumstances means.
2. Take time with novices to explain the mechanics (such as who will be there, what a court reporter does, the swearing in process etc.), the discovery process and your role at the deposition, including:

a. the role of objections and

b. the
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