My third tip for giving an effective deposition is do not get emotional.
When you are giving a deposition, often times the subject matter is sensitive. It will deal with, sometimes a very serious injury. Some of the harm that may have come to you because of that injury. How the event unfolded that caused your injury. That’s difficult for people to talk about sometimes. Even under ideal circumstances, but a deposition is anything but an ideal circumstance because in the case of a deposition, you usually don’t have a sympathetic listener. You don’t have someone who’s trying to empathize with you. You have just the opposite. You have someone who is trying to minimize the harm that you’ve suffered or to try to shift the blame for that harm away from their client and often times directly onto you. That’s painful. That hurts people sometimes. They get emotional. They tend to get even more emotional because all of the attention is on them. That attention has a tendency sometimes to bring emotion to the surface. You really need to do the best you can to suppress that emotion during the deposition.
There’s several things that you can do to be able to do that during your deposition. One thing is practice. I spend a lot of time with my clients practicing how to answer questions in the deposition. If you’ve heard questions over and over again, then it makes it easier for you to respond in a cool and unemotional manner. Another thing that you can do that’s very effective for keeping your emotions in check during a deposition is to just slow down. When a question gets asked of you, pause, let some time pass. Collect yourself. Ask over and over again in your mind, do I really understand what the question is that’s been asked of me? How am I going to answer this? Let me think about this before I launch into my answer. Let me think about what I’m going to say. There’s so many benefits to that.
One of the benefits is it’s going to give me time to object to the question if I believe that an objection is appropriate. The biggest benefit is it’s going to allow you to answer the question more effectively. That is my synopsis on my third tip for giving an effective deposition. Do not get emotional.
Please view my other videos on my top seven tips for giving an effective deposition. Click through on any of these options and you’ll find me going into greater detail and analysis: