Most of us recognize that preparation is the linchpin of good trial work. As one trial lawyer said, “Everything else- felicity of expression, improvisational brilliance- is a satellite around the sun. Thorough preparation is that sun.” Hence, we spend substantial time preparing our clients to testify at trial. In most cases, however, the client’s deposition is his trial testimony, because most cases settle before trial. Maximizing results for our clients may depend on thorough preparation of the client for deposition.
by R. Lee Livingston
Published in The Journal of the Virginia Trail Lawyers Association, Winter 2oo1-2002
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