Deposition Scheduling of our Clients or Witnesses

Big Picture

Scheduling of depositions of our clients/witnesses is a common procedure that we want to make sure we do exceptionally well. So we have to document the steps, and make sure to refine them as we learn more about how to do this common procedure more effectively.

In his book, The Power of a System, John Fisher admonishes that: “It is very important to schedule the depositions before the deadline set forth in the preliminary conference stipulation and order”  See pgs.117-130.

  1. 1

    Contact our clients or our witnesses

    1. Contact our clients/witnesses and check their availabilities. Obtain at least 2 dates, one definite and another alternative, clients should be available all day.  Check those dates in [handling attorney's] calendar.
  2. 2

    Contact the Defense team

    • Speak to their deposition scheduler or the immediate assistant to the defense counsel on file for the case)  and notify them of the plaintiff’s availability. 
    • Start by providing the definitive date and provide alternate date available only if necessary
    • Be sure to end the call with defense, with a date and time confirmed, get the person’s name and email
    • Depositions should not be scheduled later then 10am for all parties, because it can take up to 8 hours.
  3. 3

    Follow up with an email

    • Follow up with an email to the effects of “Per our conversation earlier we have confirmed the deposition of (plaintiff (s) name) in the (–matter).
  4. 4

    Calendar the scheduled date

    • Enter the date and time in calendar.  Notify paralegal in order to send confirmation letter.
  5. 5

    Re: court reporter/videographer?

    • If we are to schedule the court reporter (which we would not likely do) contact the appropriate videographer and stenographer or the court reporting firm, providing them with the confirmed deposition details.  
    • Always obtain an email confirmation in order to file into our practice management system, and to forward to all necessary parties
  6. 6

    Learn how to systematize

    Learning how to document important workflows is an important Key To Creating Systems. To learn more about doing this for your firm, check this out.
  7. 7


If you still have a question, we’re here to help. Contact us.