A Checklist addressing how to prepare a party fact witness for their deposition in an action pending in the New Jersey Superior Court, Law Division, Civil Part or in a non-foreclosure action in the Chancery Division, General Equity Part. This Checklist identifies the initial steps and strategic considerations for counsel when they receive the deposition notice, including reviewing and analyzing it, contacting the witness or client, communicating with the attorney noticing the deposition, and staying organized. It also explains how counsel should prepare for the deposition by identifying relevant documents and information, drafting an outline and mock deposition questions, assembling a witness prep binder, and meeting with the witness for a prep session.