A Practice Note explaining the steps counsel should take before preparing a fact witness for their deposition in actions pending in the New Jersey Superior Court, Law Division, Civil Part or in non-foreclosure actions in the Chancery Division, General Equity Part. This Note explains researching the claims and defenses, developing the case theory and themes, and identifying potential testimonial privileges before the preparation session with the witness (witness prep session). It also explains how to review and select documents to show the witness, assemble a witness prep binder, and draft an outline with mock deposition questions to use during the prep session.