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 or in nonforeclosure actions in the Chancery Division, General Equity Part. This Note explains what counsel should do before the deposition, what to bring to the deposition, the objections that the defending attorney may make, how to respond to the deposing attorney's requests for documents, how to handle unexpected situations with the witness, and how to obtain the transcript.