Letter To Plaintiff-Client Re Scheduled Depositions

[Date]

[Name of Client]

[Address of Client]

Re: [Name of Case]

Dear [Name of Client]:

Please be advised that your deposition in the above referenced matter will be taken as follows:

[Day, Date and Time of Deposition]

[Location of Deposition]

[Address and Phone Number of Deposition Location]

Please meet me there at [Time] to prepare for deposition.

We will discuss your case and the deposition. Please dress appropriately for the deposition (no blue jeans please). Also, please read the enclosed Your Discovery Deposition completely. Also, contact ________ of my office upon receipt of this letter to confirm your appearance.

Thank you for your attention to this matter. I am looking forward to hearing from you in the very near future.

Very truly yours,

___________________

[Signature of Attorney]

Enclosure

YOUR DISCOVERY DEPOSITION

Under the rules of practice in [State], each side in a lawsuit has the right to take the discovery deposition of the opposing party. In its simplest form, a discovery deposition is the oral testimony of a witness or party taken under oath before trial. Your deposition is one of the most important steps in your lawsuit. The attorney from the opposing side will be asking you a series of questions under oath and recorded by a court reporter. These questions will include finding out about you, your educational and employment background, prior medical history, the incident which caused your injury, your treatment and injuries from the accident, among other items.

**This document is an attorney/client communication and is privileged. Do not show it to anyone else and dispose of it after you are finished with it.**

1. PURPOSE OF DISCOVERY DEPOSITIONS

Most importantly, the other attorney will be evaluating you to see what kind of a witness you will make in front of a jury. If you make a good impression, this will increase the likelihood of a successful resolution to your lawsuit. Also, the other attorney is trying to find out all the facts which you have in regards to the incident, your injuries and doctors and hospitals you have seen.

The following information and instructions are offered in an effort to give you an understanding of what will go on, what is expected of you at the deposition and how you can be an effective witness. Despite giving you this information now, we will still spend approximately one hour before the deposition to go over your testimony.

2. YOUR PHYSICAL APPEARANCE & PREPARATION FOR...