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The deposition as ‘open book test’

WILLIAMSBURG—New Jersey P.I. lawyer Tom Vesper was one of the VTLA’s featured speakers at the group’s annual convention this past weekend in the Colonial Capital.

His topic: New ideas for taking depositions, including how to protect your plaintiff when he or she is deposed by the other guy.

One suggestion: Client Cliff’s Notes. In other words, as part of your preparation, have your client put together notes, time lines, photographs and diagrams to help her answer the defense lawyer’s questions. Also, your client can write out a list of physical complaints that result from the accident.

The other side will complain that the dep is “not an open book test,” he said.

“Oh yes it is,” he thundered. There is “no rule, no case law, no statute and no precept” that prevent you from bringing in those materials to help the person being deposed.

“This one technique has saved many, many dollars for my clients” over the years, he said.

One comment

  1. Good idea! I have often had clients complain to me in advance, “I know I’ll be nervous – what if I forget something important? Besides, I’m not good at dates of when things happened.” This sounds great. I’ll have to give it a try. Excellent plan!

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