Deposition preparation should not be a reflex exercise. Simply relying on your tried-and-true deposition preparation outline with the long list of ancient commands (“Don’t guess!” “Don’t elaborate!” “Don’t volunteer!”) is wrong. All witnesses are not created equal, so your next deposition preparation session should not be the same as your last.
It troubles me when our profession is reduced to jokes. If the public perception of lawyers perpetuates the jokes and negative portrayals, and if those jokes and portrayals bother us, what can we do to change the public perception?
Why must a defendant wait until the deposition of a plaintiff’s treating physician to discover the doctor’s opinions on injury causation, the plaintiff’s prognosis, or the permanency of the plaintiff’s injury?