After discussing the advantages of taking depositions from opposing parties and their witnesses, the article discusses practical consideration such as how a deponent's counsel should prepare the deponent for the examination and how the examining counsel should prepare for the questioning. This is followed by a discussion of the practical and tactical aspects of obtaining stipulations, with the most common being the waiving of the filing of the transcript and other related formalities and preserving to the time of trial all objections except as to form. A section addresses the obviation clause (Rule 32(d)(3)(A)) of the Federal Rules of Discovery, which preserves to the time of trial all objections except as to form. Other sections of the article discuss the importance of making a full record of the deponent's knowledge and information, marking as exhibits for identification all documents before questions are asked about them, and conducting the examination in a friendly and civil manner. Other topics considered are the deponent counsel's handling of ambiguous questions from the examiner, the length of the examination, and the examiner's assessment of deponent counsel's cross-examination of his own client.