Fourth Key To Alabama Plaintiffs Being Prepared For Depositions – Only Answer The Question Asked
Once you have heard the question, understood it, and thought about the truthful answer, the time has come to answer the question and only the question. In some ways, this is the hardest thing in a deposition.
The reason is that often defense lawyers ask questions that “suggest” something negative. For example, “Isn’t it true that you did not even go the emergency room on the 24th when the wreck happened?” The factual and truthful answer may be “Yes that’s true” but we want to add a “but I did go the next day” or “but I thought I was OK and then couldn’t move in the morning” or some similar answer. We don’t want to leave the wrong impression or allow the defense lawyer to create the wrong impression so we start to “explain” or “argue” or “expand” our answer. This must be avoided.
Your obligation is to simply answer the question. Not the unasked question (“I knew she was going to ask me how fast I was going so I went ahead and answered it”). Your obligation is not to argue or explain unless you are asked to do so. You have to trust your lawyer to know in a deposition when to ask you questions and when to save certain matters for trial.
So, as a recap – when a question is asked:
First – did you hear it
Second – did you understand it
Third – think about the truthful answer
Fourth – only answer the question.
There is much more to being prepared for a deposition but we hope this series of articles has been of some benefit to you. As always, if you are not represented by a lawyer and would like to discuss a personal injury claim with us, please fill out the “contact us” form on the left hand side of this blog and one of our lawyers will personally respond to you the same day
