"I have to give a deposition. What should I do"?
We even get this question from people who are not our clients. These are the most important things that we tell our own clients:
Listen to the whole question.
Do not interrupt.
Even if you know where their attorney is going with the question. It makes it hard for the reporter, and their attorney will just ask the whole question again, because when you interrupt, they often lose their place.
Wait a couple of seconds before you answer, to make sure the question is finished, and to give your attorney a chance to object.
Only answer the question asked. Don't give a summary of what the attorney is eventually going to ask. That does not save time, it drags time out.
Tell the truth.
Not telling the truth to the opposing lawyer is the second best way to ruin your case. (Not telling the truth to your lawyer is the first best way). What we say in our firm is, " just tell the truth, warts and all," paraphrasing Oliver Cromwell as he sat for his portrait.
Don't explain your answer.
The other attorney probably knows what your explanation is, or does not care. You can give your explanation later, with your own lawyer helping you make sure you get your whole story out, but during direct examination in your deposition is not the time. Explaining your answer in direct will make the deposition last forever.
And we say "Let truth be your armor, your sword and your shield." Not only is honesty the best policy, it is the most rewarding, financially, and morally. Never try to improve your case by stating what you think works better. Also, the truth is a huge time saver.