Here are a few things you can do to ensure that your deposition goes as smoothly as possible:
Let the lawyer ask a complete question before you start to answer. Questions may be phrased in a way that is confusing or require information other than what you’re expecting. Always pause before answering to make sure the whole question has been asked and to give your lawyer the opportunity to object to an improper question.
A court reporter will be writing down everything that is said for later reference, so avoid nonverbal responses (such as nodding), and make sure you speak clearly.
Keep answers short.
It is usually best to answer questions with a simple yes or no. Resist the temptation to offer a long explanation or to give too much information. You should also avoid sharing any information that is confidential or privileged between you and your attorney.
Don’t make guesses.
If you don’t understand a lawyer’s question, you can ask the lawyer to repeat it or rephrase it. If you don’t know the answer to a question, don’t make a guess. It’s perfectly acceptable to respond, “I don’t know” or “I can’t remember.”