Depositions should never be treated as simply “the next step” in litigation. Instead, there should be a plan as to whether depositions will be used to explore unknown facts or at trial. Too often, lawyers default into a fact-finding mission at a deposition and neglect to solidify the deponent’s sworn testimony in a way that can be used during a cross-examination at trial. This article focuses on key issues attorneys should consider when taking depositions for effective use at trial.