Lie. Begin an answer with Well to be honest with you2026. Guess and speculate. Engage in casual conversations with the court reporter and other people present in the depositions. Volunteer information. Don't review documents carefully. Lose your temper. Don't take breaks.
Hearsay. You're free to object to a question of hearsay during a trial. Assume facts, not in evidence. It depends. Calls for an opinion. Speaking and coaching objections. Privilege. Form. Mischaracterizes earlier testimony. Asked and answered.
A motion to quash, by itself, does not stop the deposition. You will have to get the hearing advanced to a date before the deposition date.
In most types of cases, for the deposition of a party to the case, you must provide at least 10 days' notice if personally served, and 15 days' notice if served by mail within California (California Code of Civil Procedure (CCP) § 2025.270(a), A§ 1013).
RULE 30(B)(6) SHOULD REQUIRE AT LEAST 30 DAYS' NOTICE IN ORDER TO ENSURE PROPER PREPARATION, AND THE DEPOSITION SHOULD BE SCHEDULED AT A TIME AND DATE AGREEABLE TO BOTH PARTIES. A. Reasonable Notice Is at Least 30 Days Prior to Deposition.
A change is made in new Rule 32(a), whereby it is made clear that the rules of evidence are to be applied to depositions offered at trial as though the deponent were then present and testifying at trial.
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.
Federal Rule of Civil Procedure 30(b)(6) appears to be straightforwardit allows a corporation or other entity to designate a witness to testify on the organization's behalf and requires only that the designated witness be able to testify about information known or reasonably available to the organization. As a
Never Guess to Answer a Question. Avoid Any Absolute Statements. Do Not Use Profanity. Do Not Provide Additional Information. Avoid Making Light of the Situation. Never Paraphrase a Conversation. Do Not Argue or Act Aggressively. Avoid Providing Privileged Information.