Deposing Plaintiffs in Employment Litigation


This practice note discusses how to prepare for and take an effective deposition of the plaintiff in an employment litigation, and includes sample questions. Although it focuses on issues that commonly arise in employment discrimination and retaliation cases, many of the tips and steps discussed below transcend that context. For checklists and forms on preparing for and taking depositions, see Deposing Plaintiffs in Employment Litigation Checklist and Sample Deposition Questions Concerning the Plaintiff’s Allegations of Discrimination, Harassment, or Retaliation.