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How To Prepare for a Deposition - continued
Previous
Some other remarks:

Depositions are more less in control of the one who calls it.  If the Agency called it, it determines
the time, location, and how long it lasts.  Agency only needs to notify you in advance as much as
possible.

As already stated, if you are currently employed by the Agency you filed against, you are supposed
to be on the clock for the deposition or the hearing.  Be sure to ask for reimbursement for travel
and gas, if applicable.

The objective of a deposition, if called by the Agency, is to get out of there as soon as possible.  
More you say, more questions you will invite, and the longer the session will be.

To stress this once again, most questions can be handled by one word: Yes or No.  “I don't know”
is a valid answer.  But don't say it when you do know or when you can estimate.

Again, most other questions can be handled by answering: what, where, or when.  Again, don't
explain more than that, unless asked to explain or to elaborate.

Know what you stated in the complaint and try to recall dates, names, what was said by the
manager when you reported or complained.  Names of the witnesses are important to remember.  
If you don’t have their contact information, you can always provide them later.

Don't try to prove the case at the deposition.  It is a wrong place to do so.  Sometimes it is better not
to show your A’s card or all of your cards at the deposition.  If you do, you are only giving the
opposing counsel more chance to prepare to discredit your evidence.  

Agency may show you some documents from the file.  Examine carefully before answering any Qs
regarding the documents.  If the document is suspicious or if you have never seen it, say so.  

Don't argue with the attorney.  Just say no or I disagree or that's not true; and leave it at that.

When asked about a document, and if you don't remember if you have it or not, you can say: “I will
look to see if I have it; and if I do, I will provide as soon as possible” or something to that affect.

If a document was talked about or was presented to you early on in the deposition, you can always
request to see it once again, if you need to, later during the deposition, in order to clarify or amend
your answer.  

You cannot ask to see what the other attorney has in her file, unless the document was mentioned
or presented during the deposition.



If you read all these "do's" and "don'ts," you deserve a break.  Here are some funny exchanges between the
witness and the attorney taken from a real court transcript..
 Click here.
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