A Practice Note explaining how to conduct a witness prep session before defending the deposition of a fact witness in an action pending in the New Jersey Superior Court, Law Division, Civil Part or a non-foreclosure action in the Chancery Division, General Equity Part. This Note discusses how to explain a deposition and proper conduct to the witness, identify the witness's relevant knowledge, review key documents with the witness, and ask the witness mock deposition questions. This Note also identifies special considerations for difficult witnesses, senior executives, and nonparties.