California employment litigation.
What should I expect for a deposition? What advice do you have that you recommend I do and don't do? I heard there is a difference between saying "I don't recall" versus "I don't remember."
What is the best thing you’ve seen your clients do during a deposition against opposing counsel’s tactics? And what was the most devastating thing you seen your client do?
As stated by the first attorney, there is no difference between the difference you presented. Assuming you have an attorney request that he or she spend a couple of hours with you to familiarize you with the process and they kind of questions you will be asked. The questions may not come in order of the facts and you may be asked the question more than once, (slightly different), so listen to the question very carefully and ask for further explanation if you don't understand the question. As stated earlier by the other attorney. don't make things up and be truthful.
My response above is only general, legal and business analysis. It is not "legal advice." It is my own analysis based on the limited brief summary you presented. Other attorneys may have a different analysis and opinion especially if more facts are considered. I am not your attorney until retained by a written retainer agreement signed by both of us. I am only licensed in the State of New Jersey.
No difference between I don't recall and I don't remember.
Best advice, take a breath, only answer the question and tell the truth.
Worst action: "tell a story" instead of answering questions.
The above is general legal and business analysis. It is not "legal advice" but analysis, and different lawyers may analyse this matter differently, especially if there are additional facts not reflected in the question. I am not your attorney until retained by a written retainer agreement signed by both of us. I am only licensed in California. See also avvo.com terms and conditions item 9, incorporated as if it was reprinted here.
Keep it short and sweet. Don't volunteer information that wasn't requested and certainly don't started becoming argumentative or attributing legal significance to things you're emotional about.
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