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
- Tell the truth.
- Listen to the question. Pause. Think as long as necessary
- Donít pause too long before answering.
- Make sure you understand the question. Donít answer unless and
until you do.
- If you donít understand the questions, say so. Ask the
questioner to explain, repeat, or rephrase the questions.
- Answer clearly and directly.
- If you donít know the answer, say ďI donít know.Ē
- If you donít remember the answer, say, ďI donít remember.Ē
- Donít confuse ďI donít knowĒ with ďI donít remember.Ē
- Where appropriate, qualify your ďI donít rememberĒ answer. Say
something like, ďI donít remember at this momentĒ or ďI donít
remember without looking atĒ the document in question.