[Captain Ahab Jr]

Originally Posted by drcoastline

Simply reschedule the deposition at a time and place convenient for you. It happens all the time. You must comply with the subpoena but you need not comply on their terms. No big deal.

If you don't want to be called as a witness for either side, your answer to every question is I don't recall. Give your name, address, position at the job etc. The answer to everything else. I don't recall.

The purpose to depositions is to get your answers to questions that they may ask in court so they know the answer ahead of time. So they know what they can and can not use. If your answer differs that's where they can get you. But if during depositions you answer I don't recall. chances are you won't get called at all because they don't know what you will recall during court.

sneaky but I like it