Immediately following the deposition, the paralegal who attended the deposition should

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The paralegal should summarize the deposition as soon as possible while it is still fresh in their memory, in order to assist the attorney in case preparation and to identify any necessary follow-up questions or document requests. Waiting for the typed record, preparing interrogatories or requests for production would come later in the case process.

Immediately Following the Deposition, the Paralegal Who Attended the Deposition