Here is something that makes for an uncomfortable deposition for an employer. The plaintiff's lawyer shows the deponent — who may be an HR person or a manager — a document criticizing the employee, perhaps even terminating her. The plaintiff’s lawyer asks, "Who wrote the document?" The deponent answers, "The lawyer for the company did, and I signed it."
Avoid this. Juries see the document as a lawyer trick. Instead, have the HR person or the manager write the document first, maybe do an outline, and send it to the lawyer for review and rewrite.
A jury sees this as normal. They think, "That makes sense." Yes, it creates more work on the front end for the client, but it results in fewer problems in the long run. Clients may balk at the proposal — "Isn't this what I’m paying you for?" — but an explanation suffices. The light bulb goes off.