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Rivertown Law
Prep questions for the Henderson deposition
Help me prepare for Marcus Henderson's deposition next week. What themes should I cover?
Good place to start. I'd organize prep around four themes: 1. **The lease itself** — make sure Marcus can speak clearly to Section 11 (maintenance) and who was responsible for HVAC. 2. **The timeline** — when the HVAC failed, when it was reported, and the landlord's response. 3. **Communications** — the email thread and any calls with the property manager. 4. **Damages** — costs Marcus incurred and any business impact. Want sample questions for each?
Yes, give me a few sample questions for the timeline theme.
Timeline questions to rehearse with Marcus: - When did you first notice the HVAC wasn't working? - How did you report it, and to whom? - What did the landlord or property manager say in response? - How long did the unit stay down before it was addressed? - Did you keep any records — emails, texts, receipts — of those interactions? Rehearsing these keeps his answers consistent and calm under questioning.
What if opposing counsel asks something we haven't prepped for?
Coach Marcus on three simple habits: 1. **Pause and listen** to the full question before answering. 2. **Answer only what's asked** — no volunteering. 3. If he doesn't know or remember, it's fine to say **"I don't recall"** rather than guess. And remind him: you'll be right there, and can object or ask for a break if needed. Preparation plus those habits handles almost anything they throw out.