The Journal Record, November 19th, 1999
A number of years ago, I was preparing a businessman/client for his deposition in a pending lawsuit. We spent considerable time going over the facts of the case and I outlined for him the areas of questioning he could expect from opposing counsel. After looking through all the documents and discussing possible inquiries, I suggested we do some role-playing. I would be the opposing lawyer who was to ask him questions during the deposition. He should give me answers just as he would in the deposition.
"Now there's one thing to keep in mind above all else, John," I warned solemnly. "Be sure to a...
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