Ten Rules for Every Deponent
There are literally hundreds of bits of advice you could give
your client before his or deposition. Next time, keep these 10 in
mind:
- Tell the truth.
- Listen to the question. Pause. Think as long as necessary
before answering.
- Don’t pause too long before answering.
- Make sure you understand the question. Don’t answer unless and
until you do.
- If you don’t understand the questions, say so. Ask the
questioner to explain, repeat, or rephrase the questions.
- Answer clearly and directly.
- If you don’t know the answer, say “I don’t know.”
- If you don’t remember the answer, say, “I don’t remember.”
- Don’t confuse “I don’t know” with “I don’t remember.”
- Where appropriate, qualify your “I don’t remember” answer. Say
something like, “I don’t remember at this moment” or “I don’t
remember without looking at” the document in question.
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