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At this point, the court reporter will administer an oath to the deponent. After that, you can dig into your outline with the standard opening question, "Please state your name for the record," or, if you want to sound like an old pro, "Tell us your name, please."
Notice of Deposition Location; Date and time of commencing the deposition; Name of deponent; Address and telephone number of non-party deponent; Any materials to be produced by the deponent at the deposition;
The attorney for the defendant has requested your deposition as part of the discovery which you must provide in your lawsuit. A deposition is the defense attorneys' opportunity to ask you questions about your background, your accident, and your injuries, and to explore your claim in detail.
Your notice must include the name of the deponent, as well as the date, time, and location of the deposition. If the deponent is an organization, describe what matters you will be discussing, so that the organization may appoint a representative with the most knowledge of those issues.
How to Handle a Deposition: Advice from an OMIC Defense Attorney Tell the truth. ... Think before you speak. ... Answer the question. ... Do not volunteer information. ... Do not answer a question you do not understand. ... Talk in full, complete sentences. ... You only know what you have seen or heard. ... Do not guess.
Brief and concise answers are best. If you don't know the answer, ?I don't know? is a perfectly good answer. Don't guess, speculate, or play a hunch. A deposition is sworn testimony; only say what you know to be true.
5 Steps for Responding to a Deposition Notice Analyze the documents that were served. ... Notify the party deponent. ... Decide whether to contact a nonparty witness. ... Object to defects in the deposition notice. ... Object to the production demand.
Deposition DON'Ts: Guess or speculate. ?I don't know? or ?I can't remember? is acceptable. Be anxious or stressed out. It will affect what you say and how you appear. Be defensive or angry. Never argue with the attorney. Offer information not requested. ... Talk too much or ramble. ... Talk too little. ... Be too extreme.