Sensitive Litigation Moment No. 114: In planning depositions, resist The Uninspired, The Lazy & The Half-Baked. By Dan HullMarch 21, 2022February 27, 2025Uncategorized Do some common sense work before you take a deposition. And please don’t squander the client’s budget out of sheer laziness. You are paid to work on planning discovery, too. See this one. “Do these guys ever think before they work?”