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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.

Answer Only the Question Presented.No question, no answer. A deposition is not a conversation. In this respect, be on guard when listening to the questions do not let the examiner put words in your mouth and do not answer a question that includes incorrect facts or statements of which you have no knowledge.

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.

In most cases, a deponent cannot refuse to answer a question at a deposition unless the answer would reveal privileged or irrelevant private information or the court previously ordered that the information cannot be revealed (source). However, there are certain types of questions that do not have to be answered.

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.

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.

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.

Texas Notice of Deposition

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