A Practice Note setting out the steps that counsel should take when preparing to depose a fact witness 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 confirming the deposition arrangements, ensuring that the deposing attorney is permitted to take the deposition, reviewing all relevant procedural rules, researching the law and permissible objections, understanding testimonial privileges, developing a deposition strategy, reviewing relevant documents and information, assembling exhibits, and preparing a deposition outline.