Top 4 Things to Avoid Being Embarrassed in a Deposition

I am asked all the time about how to best prepare for a deposition. Let me give you some thoughts. Read and understand the operative documents. Maybe it’s a complaint or a petition that you’ll be asked about or how you answered that complaint or petition. Maybe you’re a witness to something. Know exactly why you’re being deposed and the scope of what you’ll be asked. Next, prepare, prepare, prepare, prepare, prepare, prepare. Write out the specific answers that you want. And make sure you bring the notes and you can use them if you think that that will help you to give the best and most accurate answer. Next, answer the question asked and not what you think the question is. If you’re asked a question like, do you know what the time is? The answer is yes, not what the time is. The key is to understand and listen to the exact question asked and answered appropriately. Finally, always remain calm. Don’t allow anything or anybody to bother you. You are there for a specific and often limited purpose, and you can take as many breaks if you want. If you need to review information or speak to someone before answering, say so, tell the questioner you’d be guessing without seeing the document or speaking to the person, and you’re not required, you are not, you are not, you are not required to answer a question about a document without seeing the document, so ask for it. Talk to an experienced trial lawyer to get prepared for your next deposition.