This video is about preparing for the deposition of an opposing party or any other named party in your case. I will need your assistance in getting ready for opposing party depositions. How can you assist me? Many ways. Um, when we have our deposition planning meeting, we will discuss not only taking your deposition, which we previously addressed in the video, But my preparation for the deposition of the opposing party. During the deposition of the opposing party, I will be asking that party questions relevant to your case, and I will have generated a book of exhibits that I will use in guiding my questions.
So important exhibits that you can help me collaborate on would be, first of all, your case history. Hopefully by this point in the litigation, you've generated the case history that we previously discussed in client preparation. If you have not, please do a case history before we meet to discuss preparation for depositions. I will use that case history in generating questions that I want to ask your co-parent or your spouse about your case. Second, your communication record.
If you have not done so, please generate your communication record and do the highlights that we previously discussed in other videos. I will want to use the communication record to ask specific questions if we are doing a co-parent deposition and custody is a topic that we're going to discuss. So please review your communication record if you've already done so and make any additions or any necessary highlights. Bring that to our meeting or get that to me prior to our meeting so that I have the highlighted communication record ready for me to write my questions.
Other documents that you can review and assist me would be if we have bank records and there are transactions or credit card records, any financial records. If there are transactions you specifically have questions about, or you want me to ha— ask questions about, pull those out and highlight those. If we have medical records, sometimes medical records are very voluminous. I can subpoena a child's Mercy records and they're 500 pages. Please go through any subpoenaed records that we have yourself. They will be available in the client portal. If you want us to print copies for you, let our staff know and we can print copies. Mm-hmm. So it would help me if you went through any subpoenaed records that we had and specifically highlighted any areas where you want me to ask questions. I will always have my own questions. I've done lots of depositions. I depose people all the time. I definitely have a way that I want to address topics, and I'm always gonna have questions that I know I'm going to ask, but your assistance is crucial because if you go through those records and you highlight those sections for me, That is gonna help a lot.
So, how do you prepare for an opposing party deposition? Client history, please have it done, please have it updated. Communication record, have that ready. If you've already done it, go through any additional communication that's occurred from the last time you did a review, highlight additional things. Any subpoenaed record that we have, or record you've provided to me, especially if it's voluminous, go through and highlight questions that you have about it that you want to ask, That would be bank records, credit card records, medical records, police records, anything that we have in the file.
And if there are things that you have brought to me outside of that, that you want me to ask questions about, bring those to the deposition prep meeting. If you show up to the deposition and that is when you bring your records, I can ask questions about it. I much prefer that we do it at the deposition prep meeting. That we can have incorporated into our books, and I have those questions ready to go. So you can show up on the deposition day with some materials, but please try to do it at the prep meeting so that we can go through it. Thank you.