Sample Letter Client

Tell the truth. Speak audibly. Talk slowly. Think before you speak. Do not volunteer information; answer only the question that is asked. Be professional and polite. Take breaks as necessary (usually one per hour) If you do not understand the question, then ask for clarification.

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.

Don't guess, speculate, or play a hunch. A deposition is sworn testimony; only say what you know to be true. On the other hand, don't use this tip to avoid giving testimony that you know. If you don't understand a question, ask for the questioner to rephrase it.

Start a deposition by explaining the process to the witness. Always be professional and courteous. Use an outline so you do not forget anything, but do not tie yourself to it. Be curious. Listen to the witness. Make sure you get the sound bite. Leave well enough alone.

Prepare. Tell the Truth. Be Mindful of the Transcript. Answer Only the Question Presented. Answer Only as to What You Know. Stay Calm. Ask to See Exhibits. Don't Be Bullied.

Don't guess, speculate, or play a hunch. A deposition is sworn testimony; only say what you know to be true. On the other hand, don't use this tip to avoid giving testimony that you know. If you don't understand a question, ask for the questioner to rephrase it.

Deposition by written questions is essentially the same as an in-person, oral deposition, only the attorney's questions are written down and approved before the deposed person is required to answer them.

Use Clear Language. Whether in court or in a conference room for a deposition, it is always advantageous to rely on using clear, concise language instead of a building complex, jargon-filled questions. Ask About the Basics. Don't allow the basics of the case to simply be assumed. Anticipate Answers.

Skip three lines and enter "Deposition of name of person being questioned." Skip one line and enter "Court Reporter:" justified to the left and the name, address and phone number of the court reporter justified to the right. Set up your word processor to number lines and pages beginning on the second page.