Types of Deposition Questions

Answer:

One of the things in deposition prep that we always get from clients is, “What are they going to ask me about?” The answer is they can ask you about anything. They could ask you what time the sun came up this morning and what you ate for dinner last night and did you want the Dodgers to win the World Series, or were you rooting for the Rays? They can ask you anything about that. They should limit their questions to those that are relevant to the case. That could include background information, if you’re married, your children, where you grew up, your education. Have you’ve ever been sued before? Have you ever sued someone before? Have you ever had your deposition taken before? How did you apply for the job? Who told you about it? Have you ever been the victim of any crime? There’s a number of things they can ask you about. Eventually, they’ll drill down to the facts of the case because, again, the purpose of the deposition is to get some type of testimony on record regarding the facts of the case. We have seen some deposing attorneys ask some bizarre questions, and clients ask, “Do I have to answer that?” If that’s what they want to waste their deposition time on, asking you about what the breed of your puppy is, well, that’s on them; they’re wasting their time. They only have a limited amount of time. If they start asking questions that are badgering to you or in a way that you are being badgered, then your attorney will step in and put an end to that and go from there. The short answer is they can ask you questions about all kinds of crazy stuff. Answer truthfully. If you don’t know, you don’t know. If there’s a relevance issue concerning what they’re asking you, your attorney will speak up and put an end to all of that stuff.