Strategic Support: Paralegal’s Role in Depositions

• May 11, 2026
• Firm News

In April, Brian Franciskato and Amanda Cryderman delivered a virtual Lunch & Learn presentation to the Products Liability Section of The American Association for Justice (AAJ) titled “Strategic Support: The Paralegal’s Role in Depositions.”

Brian currently serves as Chairperson of the Products Liability Section, and Amanda serves as Chairperson for the Paralegal Affiliates of the AAJ.

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Strategic Support: The Paralegal’s Role in Depositions

A practical guide to maximizing paralegal impact across every phase of the deposition process.

Key Takeaways

• Strong Preparation. Thorough pre-deposition work improves outcomes and reduces surprises.
• Real-Time Support. Active engagement during the deposition enhances attorney performance.
• Consistent Follow-through. Post-deposition coordination strengthens the case and protects the record.

Paralegals drive deposition success. Strategic involvement at every phase is essential.

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Three Key Phases of the Deposition Process

Phase 1 – PRE-DEPOSITION

Scheduling & Notice:

Laying the foundation for a smooth deposition starts with clear communication and precise coordination between all parties.

• The paralegal manages communication with the court reporter and videographer, confirms logistics,  and ensures all scheduling and notifications are properly sent.
• The attorney outlines the deposition strategy and prepares the witnesses, whether they are Fact Witnesses (those with firsthand knowledge of the case) or Corporate Representatives (30B6 witnesses) speaking on behalf of an organization.

Exhibit Management:

Organization drives efficiency. Well-managed exhibits keep the deposition on track and protect the record.

• The paralegal manages exhibit logistics, ensuring all materials are provided to the court reporter and opposing counsel, and maintains a master exhibit list.
• The attorney prepares the exhibit outline, identifies all exhibits, and integrates them into the outline.

Strategy & Team Preparation:

Paralegals add strategic value by facilitating a pre-deposition team meeting that aligns everyone on goals, priorities, and potential opportunities.

• Conducts the team meeting. Review the deposition outline and align on objectives.
• Prioritizes topics & exhibits. Rank each subject matter and exhibit by strategic importance.
• Identifies gaps & opportunities. Surface inconsistencies, missing information, and areas worth exploring.

Phase 2 – DEPOSITION 

Paralegals allow attorneys to focus entirely on questioning—not logistics. Active, engaged support during the deposition strengthens the record and the case.

• Track exhibits in real-time.
• Take strategic notes, capturing key testimony, issues for additional discovery, and potential motions in limine.
• Evaluate credibility, documenting specific examples of witness inconsistencies or evasive responses.

Phase 3 – POST-DEPOSITION 

Ensuring nothing is missed after the deposition closes is just as critical as the preparation that came before it.

Paralegal Responsibilities

• Calendar all deadlines and follow-up dates
• Distribute exhibit copies to the court reporter and opposing counsel
• Coordinate expedited transcript, if necessary
• Calendar 30-day transcript review and protective order deadlines
• Review errata sheets once received
• Outline additional discovery based on testimony

Attorney Responsibilities

• Discuss strategy and timing for Motions in Limine with the paralegal
• Identify problematic testimony and flag any evidentiary issues
• Prepare a list of initial deposition designations and possible video cuts
• Highlight key admissions and favorable testimony
• Identify testimony that supports the trial theme

Paralegal involvement is not optional—it’s strategic. When paralegals are empowered at every phase, the entire legal team performs at a higher level.

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About the Presenters

Amanda Cryderman

Amanda has been an integral part of the Nash & Franciskato team since 2010. She is Chairperson for the Paralegal Affiliates of the AAJ and holds a leadership role in the Kansas City Paralegal Association. Currently, Amanda manages the firm’s Mass Torts Division, where she oversees more than 500 clients.

 

 

 

Brian Franciskato

As a partner at Nash & Franciskato, Brian represents plaintiffs in serious personal injury and wrongful death litigation, with a particular focus on mass torts involving defective medical devices. A longtime AAJ member, he currently chairs the AAJ Products Liability Section and serves on the Membership Oversight Committee.

 

 

About the Organizations

Nash & Franciskato Law Firm is a firm dedicated to nationwide representation of clients affected by automobile and trucking accidents, wrongful death, product liability, defective drugs, medical devices, and other related issues. The firm is dedicated to helping people who are seriously injured by others.

American Association for Justice (AAJ) promotes justice and fairness for injured persons, safeguards victims’ rights—particularly the right to trial by jury—and strengthens the civil justice system through education and disclosure of information critical to public health and safety. With members worldwide and a network of U.S. and Canadian affiliates involved in diverse areas of trial advocacy, AAJ provides lawyers and paralegals with the information and professional assistance needed to serve clients successfully and protect the democratic values inherent in the civil justice system.

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Past results afford no guarantee of future results, and each case is different and is judged on its own merits. The choice of a lawyer is an important decision and should not be based solely upon advertisements.

Photo Credit: kataklinger(Predrag Paunovic) – Image File – via depositphotos.com