Deposition Prep Outline for Corporate Witnesses

As litigation counsel preparing [WITNESS_NAME], [COMPANY_TITLE] at [COMPANY], for deposition in [CASE_TYPE] matter, create a comprehensive preparation outline. Your document must include: 1) Three core case themes to reinforce, phrased as memorable talking points, 2) Five anticipated hostile questions from [OPPOSING_COUNSEL_FIRM] with legally safe response templates (including proper "I don't recall" phrasing), 3) A document review checklist covering emails from [DATE_RANGE], contracts with [RELEVANT_PARTIES], and internal policies regarding [SPECIFIC_TOPIC], 4) Three dangerous phrases to avoid (e.g., "I think" or "Never") with preferred alternatives, and 5) Two mock deposition scenarios simulating [OPPOSING_COUNSEL]'s likely aggressive tactics. Format as a bulleted list with "Privileged & Confidential" footer, use bold for critical warnings, and include a section on proper document handling procedures during testimony. Keep all explanations concise and action-oriented.