|
I take depositions all the time. Your depo is the other side's chance to learn everything about you. They also do it to lock down your testimony, get you to tell them what happened, what damage it caused, your life history, etc. Then, if you go to trial, they have the transcript so they can call you out on any variations. Be very careful.
Short, yes or no answers. Do not volunteer information. Answer only what was asked. It's amazing how bad some attorneys are at getting facts crucial to their own case. The more you talk, the more you are likely to help him out.
Example:
Q: Are you married?
right answer: Yes, no, separated, divorced etc.
Bad answer: I'm in the middle of a divorce and we're fighting for custody and my soon to be ex is a *****.
Assuming this involved an accident, be prepared to go through the details of you accident, second by second down to every last detail. Also be prepared to basically give your life story. Think Goonies, when they tell Chunk "Tell us everything."
I don't know or don't recall is a perfectly good answer, but don't abuse it. People come off as stupid when they can't recall where their first job was, or where they lived 5 years ago. Also, there is a difference - not recalling implies you once knew the answer, but forgot.
Again, don't volunteer ****. Make that guy work for his answers.
|