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You are viewing ARCHIVED CONTENT released online between 1 April 2010 and 24 August 2018 or content that has been selectively archived and is no longer active. Content in this archive is NOT UPDATED, and links may not function.By Jennifer Shelfer
When a company is noticed for a deposition, it has a duty to prepare its witnesses to fully and unevasively answer questions about the designated subject matters. Companies may not realize, though, that the preparation must include not only facts known to the company, but also facts known uniquely by the company’s attorney. These facts, even if discovered solely through the company’s attorney’s efforts, are discoverable and are not protected by the work product doctrine.