California Wrongful Death Case - Discovery; Depositions

OPPORTUNITY TO REVIEW AND CORRECT DEPOSITION
Although you will have a chance to review and make corrections to your deposition, a lot of corrections would seriously undermine your credibility. Therefore, you should try to avoid the need for any later changes. If it occurs to you during the deposition that you have made a mistake, immediately inform the Southern / Northern California wrongful death attorney questioning you, and correct it then and there.

DRESS AND APPEARANCE
Your dress and appearance will affect the other side's evaluation of the appearance that you will make before a jury so it is important that you dress well. Dress as if you were going to church. Dress conservatively. Dress well but not flamboyantly. The way we dress makes a statement about who we are whether in a wrongful death case or any other kind of personal injury case.

GENERAL DEMEANOR DURING THE DEPOSITION
1. Sit up straight.

2. Avoid unnecessary gesturing.

3. Speak up.

4. Do not nod your head for an answer.

5. Do not chew gum.

6. Do not lose your temper. (Remember, the defense will be sizing you up to see how a jury would view you.

7. Be courteous.

8. No joking or wisecracking.

9. Say yes or no instead of uh-huh and yea.

10. Consider the occasion solemn and avoid getting "chummy" with opposing counsel. Normally, opposing counsel will want to be "chummy" with you to lull you into a false sense of security.

NECESSITY OF BEING TRUTHFUL
The first and most important instruction is to be truthful in your answers. This means not only refraining from telling a deliberate falsehood, but also means being accurate. Do not guess at your answer. If you do not know the answer, admit you don't know. If your memory is weak on a matter but you feel you should know the answer, admit nonetheless that you do not recall.

UNDERSTAND THE QUESTION
If you do not understand the question, ask that it be repeated or rephrased. Admit that you do not understand it and ask for an explanation.