Preparing for a Deposition

Preparing for the deposition is one of the most important things that you can do in asbestos case or any case. It's not something that you just show up to the doorstep the day before and do it. It's something that takes ten, twelve phone calls, usually two in person meetings. There's no way that I ever go into a deposition without meeting my client in person. It's amazing how different the relationship is on the phone. Sometimes a little standoffish, sometimes a little the lack of trust in the conversation. But once you show up and they see your face, you sit in their in their living room, you're on their couch, you have some water with them. You leave, it's night and day. So the most important thing is communication and letting them know the process, letting them know the duration of all the pretrial work that's going to go into it, the trial date. But most importantly, it's getting them revved up for the deposition. Because once the deposition is over, that really is the heavy lifting of the client's work on the case is over. And you prepare them and literally for every single category of questions that the defendant's assent at the end of the deposition, they look at you and go, wow. You told us every single thing that they were going to do. And I'm like, yeah, of course. You know, that's I've been doing this a long time. There's only so much that they can ask.