The client must be prepared on the substance of the case as well as on the procedural guidelines of deposition practice. The answers the client gives at the deposition lay the foundation for testimony that is given later at the trial. The lawyer and client must concentrate on the core issues of the case by reviewing key facts and documents and understanding the disputed fact issues. The procedural guidelines for defensive deposition are to tell the truth and to avoid volunteering additional information. However, the client may volunteer information to explain core issues and to avoid being tricked into answering unfairly worded questions. Finally, the lawyer should conduct a practice examination to familiarize the client with the deposition process. 5 notes