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Objections in depositions: Whenever necessary, the defending attorney raises deposition objections to prevent the witness from providing misleading, confusing, or inaccurate testimony. Generally, proper deposition objections may be made on the grounds of form, relevancy, or privilege.
Go over where and when the deposition will take place, who will be present and why, and the role of the court reporter and the videographer (if the deposition will be videotaped). Also, explain the oath. Explain what a deposition is. Describe what a deposition is so that your client is familiar with the basic process.
These courts hold that counsel's selection of documents to prepare a witness for deposition is protected attorney work product because the selection of documents by an attorney reflects that attorney's thought processes and legal theories. See, e.g., Sporck v. Peil 759 F2d 312, 316?18 (3d Cir.
The preparation of fact witnesses is protected from scrutiny by the attorney-client privilege. The ethical rules trump the desire to win a case; but scrupulous compliance with ethical rules is not the only goal of a lawyer. More is at stake.
What Is a Notice of Deposition? Witnesses are needed by a legal team to answer questions under oath pertaining to their knowledge relating to a lawsuit before the case is tried in the court. The law firm sends a document called a notice of deposition to the witness and all other parties involved in the lawsuit.