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What Should You Not Say During a Deposition? Guessing or Speculating on Things. ... Saying Things Out of Anger. ... Rambling. ... Speaking in Absolutes. ... Stick to the Facts. ... Take Your Time When Answering Questions. ... Use ?Yes? or ?No? Answers Whenever Possible. ... Get Through Each Question on Its Own.
In many cases, questions that do not have to be answered fall into three categories: Private information. You have a right to refuse any questions about a person's health, sexuality, or religious beliefs (including your own). ... Privileged information. ... Irrelevant information.
Some of the most common questions asked in this way include: What documents associated with the case have you reviewed? Have you talked to anyone other than your legal counsel about this case, and if so, who are they? How did you prepare for this deposition?
Rephrase the question into a sentence of your own, using your own words. Do not answer a compound question unless you are certain that you have all parts of it in your mind. If it is too complex to be held in your mind, it is too complex to answer.
Questions we ask include: What caused you to trip /slip and fall? Where exactly did the slip/ trip and fall occur? Had you ever been to the location of the slip/trip and fall before the incident? ... When did you realize what caused you to slip/trip and fall? Was anybody with you when you fell?