PREPARATION CHECKLIST

• Wear neat, clean, conservative clothes.
• Refresh your memory by going through all your records and become familiar with all relevant dates and times.
• Answer all questions audibly and distinctly.
• Do not guess if you do not know the answer to a question. State that you do not know.
• If you do ont understand the question, ask the attorney to repeat or clarify.
• Always tell the truth. There are criminal penalites for perjury.
• Do not volunteer information. Answer only the questions asked.
• Do not try to figure out why an attorney is asking you a certain question. He is probably fishing, and you may guess wrong.
• Do not lose your temper. You may be doing exactly what the attorney wants you to do.
• If you are asked if you have spoken to this attorney prior to this deposition, tell the truth.
• Do not be sarcastic or hostile toward the attorney.
• Be courteous to everyone involved in the deposition. Say "yes,sir" and "no,sir".
• Do not estimate anything unless you clearly state first that you are estimating.
• If you do not remember the answer to a question, state that you do not recall.
• Do not anticipate a question. Let the attorney finish the question completely before you answer it.
• If you know that the attorney has asked you a question incorrectly, do not try to correct him. Merely answer the question he has asked.
• Do not agree with attorney just to be nice or agreeable.
• Do not look to your attorney for help when answering a question.