A client’s deposition is an important part of a case.  It gives the adversary an opportunity to pick your brain about the case, but it is also your opportunity to impress him with the fact that you will make a favorable impression as a witness at trial.  At the deposition the adverse attorney will ask you questions about the case.  A court reporter will be present who will swear you in and take down all of the questions and answers verbatim.  I will be there with you, primarily to monitor the questions.  I want to make sure they are not inadvertently asking poorly worded questions.  The adverse attorney wants to know what you will testify to at trial.  For instance, he would not want to learn for the first time at trial that his client was dead drunk at the time of an automobile collision.  His questions are not designed (ordinarily) to try to trick you.  Probably the most common problem in depositions is that deponents (the people being asked the questions) are so on guard for trick questions that they end up appearing to be unable to give a straight answer. You mainly need to make sure you understand the question.  If you do not, for any reason, you need to say so.  You need to try to avoid uh-huhs and un-huhs and shakes of the head or nodding because those expressions and gestures are not easily transcribed by the court reporter.  You need to make sure that whoever is asking you a question has stopped talking before you begin to answer so that the court reporter does not have to try to take down two people talking at once.  I will object only if I think the question is poorly worded and even then I will still tell you to go ahead and answer, as long as you understand the question.  You need to speak up and ask the attorney to repeat or rephrase the question if you do not understand it for any reason – whether its long, or someone comes in the room and distracts you – for any reason at all.  You will only refuse to answer a question if I clearly tell you not to do so and you will have no doubt that I am doing that because I will probably be waving my arms before the question is even finished.  But it is unusual for a question to be asked which I would tell you to not answer.