Deposition Tips

Tip #1 is the most important tip of all: TELL THE TRUTH! Your credibility and your claim is at stake. Almost all cases have good facts and bad facts. We can deal with bad facts. We can't help if you are caught in a lie.

Listen carefully to every question and answer the question asked. If you did not hear the entire question, ask for it to be repeated. The deposition is not a conversation. It is a question and answer session. Make sure that you wait for the attorney to complete his full question before you give your answer. It is very important that you speak clearly and respond with verbal answers only (no shakes or nods of the head).

Understand the question that is being asked. If you do not, ask for clarification.

Do not guess or speculate. If you do not have knowledge about the subject matter being asked, or if you simply do not know the answer, it is perfectly acceptable to say so, even if the attorney asking questions tries to push you for an answer!

Remain calm and be polite. Remember that opposing counsel is not only listening to each answer, he is judging how you answer and your body language. Let your attorney step in if the attorney asking the questions becomes too argumentative.