Section 4.36 Preparation for Use at Trial

• Library: Discovery 2015

The following should be considered in preparing to use a deposition at trial:

· If some questions were not answered, a motion to compel answers should be considered and, if successful, depositions for those purposes should be scheduled and taken.

· Any changes to the depositions desired by the client or witness should be properly made.

· If signature was not waived and the deposition is to be used as evidence or as admissions of a party, counsel should obtain the witness’s signature or be prepared for...