It is a question and answer session. It is not the same as a regular conversation that you would be having. There generally will be a question and you can take a moment to think about the question, then answer it. It should not feel like a normal conversation, you want to make sure you think about what is being asked before you answer and make sure you are accurate as possible.  The pause or minute before you answer, make sure that you are not going to say something that you are going to later regret saying. It gives you a little bit of time to be in more control.  You should answer the question, but it should not be a long answer. Generally, your answer should be about a sentence.  The defense attorney is the one asking the question and they have to ask the right questions and you just have to answer. Even if you feel that it is incomplete, you should not necessarily try and volunteer things that are not being asked about.

Another thing that is important is that you need to dress appropriately for the deposition. Appearance does matter, so dress conservatively. You want to give as honest of an answer you can and be direct in your answer.  You should pay attention to if you are getting too tired; or if you need to go to the bathroom; or need a drink, you can take a break and somewhere within the ½ hour to an 1 hour or maybe every 45-minutes it is reasonable to take a break, if you need it. It is a tiring and stressful time. It is also fair to say if you do not recall or do not remember; or you do not understand the question, you can say those things, only if that is true. You do not want to be argumentative, but if you truly do not know remember something or understand what was asked, the wording of the question, you can ask.

If they are asking a yes or no question, does not mean you have to answer yes or no. If they are referring to a report or records, you can say that you do not recall what that is, unless you actually see it or get more details about it and that you are not sure.  You also want to take a look at what is in your medical records, and those are general tips for depositions.