One of the most useful things to do in a deposition is to discredit the witness. Giving yourself plenty of time, check the witness in the following public records in the county of residence and in the county of employment: Litigation; Judgments; Federal Tax Liens; Voter Registration; Parking Violations Judgment Docket; Real Property; UCC's. If judgments are found, search back to the case from which the judgment emanated. Oftentimes, this will be in another county or state. The judgment docket, whether computerized or manual, will have the court of origin. If these or other records disclose a business name, check it also. By analyzing your findings, you may be able to discredit your witness or show a pattern of litigation that you can use to your advantage. The best advantage, though, is that the witness will have no idea that you have checked him out.