What guidelines should be followed for giving a discovery deposition?
• Tell the truth. • Dress appropriately. • Discuss matters in advance with counsel. • Do not be influenced by the examiners friendliness. • No need for the whole story. Do not be concerned that all relevant facts have not been elicited by the examiner or that s/he has created only a partial picture. You will have an opportunity at trial to present additional testimony. • If you wish, confer with your attorney before answering a question or during breaks. • Off-the-record comments: If you have a conversation with someone in the deposition room when the examiner is present, be prepared for questions on that conversation when you are on the record. • Be courteous and civil. • Avoid any attempt at levity or sarcasm. • Avoid derogatory language. • Do not make promises (including looking up information, obtaining materials, making calculations, etc.) unless cleared first with your attorney. • Do not become involved in the arguments of counsel. • Answer only the question that is asked. • Spea