Being good at most things involves knowing what you are doing and working hard. Preparation is the key to success. Whether it is a trial, a deposition, interrogatories, trial briefs, whatever, calendaring it, and working on it before it is due, makes the final product all the better. For depositions, it is always better to meet with the client before hand, explain a deposition, and let them know what to expect. As with most cases, they drag on forever, and many people forget what they have previously said, or their memory is a bit hazy. Going over the documents in the file one or more times prior really helps refresh the memory. Depositions are under oath, so whatever is said, the client is stuck with, make sure they are stuck with the answer that is the correct one.