Deposition Tips for Both Plaintiffs and Defendants
Whether you are a plaintiff or a defendant in a Massachusetts personal injury lawsuit, there is a good chance you will be deposed. The American Bar Association provides 10 tips for deponents which I feel can help you if you are facing an impending deposition. Here they are:
- Tell the truth.
- Listen to the question. Pause. Think as long as necessary before answering.
- Don’t pause too long before answering.
- Make sure you understand the question. Don’t answer unless and until you do.
- If you don’t understand the questions, say so. Ask the questioner to explain, repeat, or rephrase the questions.
- Answer clearly and directly.
- If you don’t know the answer, say “I don’t know.”
- If you don’t remember the answer, say, “I don’t remember.”
- Don’t confuse “I don’t know” with “I don’t remember.”
- Where appropriate, qualify your “I don’t remember” answer. Say something like, “I don’t remember at this moment” or “I don’t remember without looking at” the document in question.