Deposition Preparation of Defense Witnesses Checklist (Employment Cases)

Summary

This checklist highlights how to prepare defense witnesses for depositions in employment litigation matters. Prior to defending a deposition, thorough preparation is essential to ensure deposition testimony is helpful and, more importantly, not harmful to the defending employer. Note that due to potential time limitations in preparing a witness, it may not always be possible to complete all of the steps below, but we recommend implementing as many of the steps addressed below as practicable.