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The party defending the deposition should look to see if the taker has complied with the procedures to notice the deposition. If there are objections, consider a protective order. Develop a theory of the case. In preparing for a deposition, the plaintiff should review prior written discovery and pleadings.
Often a deposition begins with ground rules:
· The witness is not to lie, guess
· Answer questions to the best of recollection
· If a witness later changes an answer after review, an attorney can refer to the change at trial
· Listen to the question, and make sure to understand it before answering
At a deposition, a plaintiff should try not to volunteer information and answer only what is asked. Silence is ok because it does not show up on a transcript unless an attorney makes note of it for the record. Do not be sarcastic or make jokes. Do not suggest or lead an attorney on to ask other questions with an answer.
When seeking to recover from an accident, look to a Hawaii personal injury lawyer who takes time to prepare a witness for a deposition.