Civil Procedure
Jul. 22, 2026
10 steps to prepare a witness for deposition
Effective deposition preparation strikes a careful balance between ensuring a witness is informed and confident without crossing the line into overpreparation that undermines truthful testimony.
Michael S. Kun
Partner and Co-Chair of the Labor & Employment Practice Group
Thompson Coburn LLP
Email: mkun@thompsoncoburn.com
Univ of Virginia SOL; Charlottesville VA
Q: "What is your birthdate?"
A: "I don't recall."
Q: "When did you graduate from college?"
A: "I don't recall."
Those are exact--or near-exact--quotes from a deposition I attended more than 30 years ago, when I was an associate at a large national firm.
The deponent was a key witness in a trade secret case. He had been wildly overprepared over the course of thre...
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