It is always important to prepare for deposition, but remembering these basics will also play a crucial roll in making things go smoothly.
- TELL THE TRUTH
- Listen to the entire question prior to answering
- Do NOT answer if you did NOT hear or understand the question
- Answer only what was asked
- Be concise in your answers
- Do not feel the need to fill the silence between questions
- Do not guess – if you do not know simply say “I do not know”
- Remain calm – don’t argue
- Don’t try to win the case
- Make sure you mean what you say – for instance there is a difference between saying “I don’t recall” and “I don’t know.”
It may seem like a lot to remember, but most of these behaviors exist naturally within us. The most difficult and most important thing is to be precise, communicative, polite, and nothing more. Think, perhaps, dining with the Queen of England.

[...] Even if you are sued, you can take steps to avoid harming your case. Your lawyers should tell you of these rules – as well as additional items to discuss and not to discuss, but it’s important that you know the 10 things to remember when being deposed. [...]