A Practice Note setting out the steps that counsel should take in preparing to depose a non-expert deponent in Ohio civil litigation. Among other things, the deposing attorney should confirm the deposition arrangements, ensure that she is admitted in the court where the case is pending, review all relevant procedural rules, research the elements of the claims and defenses in the case and the law concerning any legal issues that may come up during the deposition, review documents and information relevant to the deponent, and draft the deposition outline.