03/06/2026
A deposition can set the tone for the case. So many attorneys ask a lot of detailed questions and the more a client volunteers information, the more they dig deeper. The hole can be too big to crawl out of. In prep for the depo, an attorney can see how open the client will be .Sometimes they client will hold back when I am asking them but then when defense attorney asks, they start opening up. Not that it is good idea to with hold information. Some times the attorney has all kinds of information and some times they do not . What is not proper is to keep asking the same thing... One attorney even would repeat back his questions and the answer and say is that correct? Sometime clients answer question with a lowering tone as if they are unsure of the answer as if they are stating their answer as a question and they are unsure. The one rule is to not make statements . One can correct to say that I had the wrong year of employment it was a year earlier but not to say, hey my memory is bad, so I am really unsure of the year.