Section 19.34 Client’s Deposition

• Library: Family Law Deskbook and 2014 Supp

K. (§19.34) Client’s Deposition

Preparation of the client for the client’s own deposition varies from lawyer to lawyer and case to case. Some prefer meticulous review of expected questions almost to the point of a pre-deposition deposition. Others feel comfortable with a general review of expected areas of inquiry. Counsel should always give the client a description as to how depositions are conducted and who will be in attendance. The following matters are usually appropriate for discussion with the client:

· Explain what...