If you have never been deposed before, you may feel quite apprehensive and nervous about an upcoming deposition. It is your job as hired and/or appointed counsel to sit down with your clients and educate them about deposition protocol and procedures and prepare them for questions they may encounter.


“Business casual” is always the best. Apparel should be conservative and traditional, not anything that may be controversial or may leave a bad impression. Clothes should be clean, pressed, and neat. Hair (including facial hair) should be washed, trimmed, and combed. Slacks and collared shirts are always good options, any jewelry should be understated and flat shoes or small heels are recommended for female clients. Your clients’ appearance should be professional and business-like.


Instruct your clients to arrive early to the deposition and familiarize themselves with their surroundings. They should find a chair that is comfortable for them and does not squeak or make any other distracting noise. Posture should be straight, not slumped, and hands should be placed on the table in front of them. Remember to instruct them not to: chew gum, or fidget with hair, clothes, papers, cell phones, or microphones.


Your clients should thoroughly listen to each question in its entirety before offering an answer. They should think before every answer and make sure that they understand the call of the question. If there is any ambiguity as to the question, they should ask for clarity; ask that the question be restated or rephrased.


Instruct your clients to always tell the truth! If your clients are uncertain of an answer instruct them to state that they do not know the answer rather than guess and be wrong.


Your client should always help themselves and not volunteer more information than what is asked. If the call of the question asks for a yes or no answer then they should just simply answer with a yes or no and then stop talking.

NAEGELI Deposition & Trial has been known as the industry’s leading choice for court reporting and litigation support for over 40 years. We have assisted in thousands of depositions over the years and are ready to serve you 24 hours a day, 7 days a week. Call our experienced team today at (800) 528-3335.