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One of the most important things about preparing witnesses for deposition is making sure they are very familiar with all relevant records and questions likely to be asked, so that they are not hearing and thinking about a question or looking at a document for the first time in the middle of testifying.
1. Be wary of any deposition question that asks you to form an opinion based on hypothetical facts.2. Be careful of questions phrased in terms of “good medical practice.”3. Be a fact witness of what you personally did, said, saw and overheard when treating the patient. Once the deposition is completed your attorney can fill you in on other matters you will need to know by the time of trial.
A health care provider’s deposition is usually the first opportunity he or she has to actively participate in the case and the importance of proper preparation cannot be stressed enough. What is said at the deposition cannot be easily changed at trial. It is often the event he or she comes to wish more attention had been given to before the deposition got underway.
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Deposition: Expectations and Tips
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Typical scenarios in the deposition
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