When an attorney defends a corporate representative deposition, it is imperative that you have your client prepare, especially as it relates to matters of which the corporate representative does not have personal knowledge. When a corporate representative answers “I don’t know” to a question directed to him/her, it can have catastrophic consequences as the representative’s knowledge represents the company defendant’s position. Thus, it is important that an attorney point out to the company defendant’s corporate representative which areas or topics he/she must prepare for in advance of the deposition.