A deposition is not a friendly conversation. The attorney asking the questions is trying to build a case against you. It is important to listen closely to the questions being asked and answer only the question that is asked. Keep your answer short and directed to the question. Once you have completed your answer, patiently wait for the next question. Many times, clients are nervous during depositions and talk to fill up an awkward silence.
if you don't know the answer to the question, DO NOT GUESS. Guessing is the worst thing you can do in a deposition. If you don't know the answer to the question, you should simply say, "I don't know." If you don't remember the answer, you should simply say, "I don't remember"
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