By Walter Williams

The best deposition I ever took was without notes or exhibits. Typically, even to this day, I game plan every question and variants of questions, depending on anticipated answers. I attempt to ask questions so well thought out, the answer almost doesn’t matter. But, this one time. I forgot my play book and had to borrow a legal pad and pen from the opposing counsel. For me, the lesson is one I have “learned” over and over: prepare so much it’s second nature.

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