Preparing Your Client for Deposition – Part 10

Additional rules of the road for your client for her deposition: 31. Don't take notes during your deposition. The interrogator will you ask you about them. 32. Be careful of questions that use absolutes, like "never" and "always." 33. Don't assume anything you say is "off the record." 34. Don't object to questions. That's what your lawyer is there for. 35. Only bring those documents to a deposition your lawyer asked you to bring. Before the deposition, show your lawyer what you brought. 36. Don't discuss the deposition in the bathroom, hallway or on the phone. You never know who may be listening. 37. Be yourself. 38. Don't let the attorney's pregnant pauses or silence compel you to keep talking. Once you're done with your answer, stop. Don't continue explaining it. 39. If the interrogator is confused or lost, don't help him. 40. Your conversations with your lawyer are privileged. Don't offer them up in deposition. 41. Avoid superlatives. 42. Whatever you say to opposing counsel will find its way into the record. Do not fraternize with opposing counsel during breaks. 43. Ask to read the deposition at the end. Do not waive the reading of the deposition. 44. If you made a mistake or misspoke during the deposition, let your attorney know before the deposition is over. 45. Try to remain relaxed while remaining vigilant. Share this: Twitter LinkedIn Email Digg Reddit StumbleUpon Facebook Like this: Be the first to like this post.

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