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.
Rivertown Law