Appendix A: Client Deposition Instructions

Appendix A reproduces the actual client deposition instructions to use with deponents, organized as a complete preparation document students can adapt to their own clinic and practice work. Sections cover deposition information and procedures; conduct expectations; the taxonomy of question types deponents will face; specific questions to anticipate; response techniques (listen carefully, answer concisely, never guess, do not volunteer); objection mechanics from the deponent’s perspective; and the conclusion of the deposition. The format is direct client-facing prose rather than doctrinal exposition. Especially valuable as supplementary reading in a deposition-skills or clinical course where students must draft their own version for real client preparation.