A Practice Note explaining how to defend a fact witness's deposition in actions pending in the New Jersey Superior Court, Law Division, Civil Part (including in the Complex Business Litigation Program) or in non-foreclosure actions in the Chancery Division, General Equity Part. This Note addresses what counsel should do before the deposition, what they should bring to the deposition, and the objections they may make. It also explains how counsel should respond to the deposing attorney's requests for documents, handle unexpected situations with the witness, and obtain the transcript.