Specify the type of deposition (e.g., expert, fact witness, Rule 30(b)(6) representative, or Person Most Knowledgeable)
Provide and explain legal source material (e.g., Rule 30(b)(6) representatives must testify about information known or reasonably available to the organization)
Briefly describe the type of case and claims at issue (example: “This is an antitrust case involving price-fixing claims in the market for legal research software”).
Note whether the witness is adverse or any other relationship to the witness (e.g., “This is the lead witness for the opposing party,” or “This is a third-party witness”).
Note anything else you would like CoCounsel to consider when generating deposition questions (e.g., “This witness is known to be untruthful,” or “This witness may have spoliated evidence”).