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What can I ask in a deposition?

New York, NY |

I am ProSe, in divorce litigation and I am taking the deposition of my ex-wife. Can I only ask questions related to finances and can I ask anything I want? For exemple, she said in her moving papers I was bipolar, can I ask her why she said that?

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Attorney answers 2


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!

Ms. Brown may be reached at 718-878-6886 during regular business hours, or anytime by email at: All of Ms. Brown's responses to questions posted on AVVO are intended as general information based upon the facts stated in the question, and are provided for educational purposes of the public, not any specific individual, and her response to the question above is not legal advice and it does not create an attorney-client relationship. Ms. Brown is licensed to practice law in New York. If you would like to obtain specific legal advice about this issue, you must contact an attorney who is licensed to practice law in your state.


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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