© D.L. Crumbley
Always tell the truth, but answer only the question asked.
Think before answering.
Never answer a question you do not understand.
Do not guess or speculate.
Do not bring notes, diagrams, books, or other written material to the deposition unless a subpoena or your attorney requires you to do so.
Listen carefully to each objection made by your lawyer.
Do not argue or become angry or hostile with the examining attorney.
Even if a question calls for a yes or no answer, ask to explain your response if you feel a qualification or explanation is required to complete your answer.
Beware of questions which involve absolutes.
Do not memorize your answers before the deposition.
Source: B.P. Brinig, “The Art of Testifying,” in , John Wiley, 1990.