I practiced law for 25 years before becoming a mediator.  For a dozen of those years, I taught deposition skills for the National Institute of Trial Advocacy.

To save the young people around me from receiving any more unwanted advice from their elders, I decided to start "data dumping" my quarter century of litigation experience in this blog from time to time.  

You'll (perhaps) be pleased to hear that today I'm not even giving my own advice but passing along that of Illinois trial lawyer Evan Schaeffer -- be prepared or the dangers of "winging" it at depositions.  

It's not so much an exhortation to work harder, but smarter that makes me refer you to Shaeffer today.  Take a look at the good questions he suggests every attorney ask herself before the deponent is sworn in and then think about Shaeffer's limitations -- in Illinois, you apparently have only three hours to take anyone's deposition.  

And we can all recall those times when someone green spent that three hours on the deponent's background ("and after that were you promoted to Eagle Scout?")