A Checklist of steps to take when preparing to depose the employer witness in an employment case. This Checklist addresses noticing and scheduling the deposition, making logistical arrangements for the deposition, researching facts and law relevant to the case, preparing the deposition outline and exhibits, and anticipating issues that may arise at the deposition. This Checklist is based on the Federal Rules of Civil Procedure but is also useful for cases pending in state courts.