It is rather impossible to coach you on taking a deposition in a few sentences online. You are supposed to ask questions that are material and relevant to the issues in dispute and on topics that you reasonably expect to be within direct knowledge of the witness. You've probably already been advised to obtain legal counsel, and for whatever reason, you've rejected that advice. Nevertheless, I suggest you at least arrange a consultation with a local attorney before you go off to your deposition--a single consultation won't fix all your problems but certainly it will help. Good luck!
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If she accused you of being bipolar as part of her "grounds," then no. You may try to ask her whether she's contenting it's relevant on any other financial issue, such as equitable distribution or maintenance. Suffice it to say, the old adage is true: those who represent themselves have a fool for a client (no offense). For a full assessment, schedule a consultation with a NYC Divorce attorney.
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