If you are ever being deposed (I.e. having your deposition taken), this is NOT the time to tell your version of events, correct the misunderstandings of the other side, or explain your defense.
There will be a time for that. It comes later.
Your job is to answer the questions, as accurately, precisely, and narrowly as you can.
The correct answer to “Do you know what time it is” is either yes or no. It’s not answered by giving the time.
Make the lawyer ask you the questions. And answer them literally. Don’t elaborate, or try to fill silence with more words.
Also, in a deposition all words are being written down. Pauses are not. So take your time being deliberate with your answer. Don’t be obnoxious about it (you don’t want the opposing counsel to say “for the record, the witness has taken 5 minutes to answer “how far did you go in school”), but you shouldn’t let the pace of the question dictate the pace of your answer.
If you don’t understand the question, say that you don’t understand. You can ask the questioner to clarify or rephrase.
If a question is compound (it asks you more than one thing, and so you can’t say yes or no to just one, such as “ As you approached the intersection, did you look down, change the radio station, and then look up and for the first time notice the oncoming car?”) don’t answer it. Ask for more specific questions.
Don’t guess. Instead say “I’d be guessing if I tried to answer that.”
Always tell the truth, but sometimes the most honest answer you can give is “I don’t recall”. If you are asked a question that you don’t know an answer to, say “I don’t know.”
If you are estimating, make it clear that you are doing so. It is helpful to preface answers with phrases like “to the best of my recollection…”, or “without having precise information in front of me, I’d estimate…”
Don’t discuss anything you spoke privately to your attorney about. That’s not something the other attorney is allowed to ask about.
You will likely be asked about your life history. It’s standard practice. This includes employment and education. If you are asked why you left a job, and it’s not material to the case (e.g. an employment discrimination case) but just background info, you can just say “I pursued a new job opportunity” so they can then ask “what was that?”
Don’t be offended if they ask about mental health as part of that background. It’s common to be asked “do you have any conditions/take any medications that might impact your memory/prevent you from answering truthfully today?” (I had one guy make a big deal out of the question about medication that wound effect memory - “Well, if I took it, how would I remember?” Just answer the basic questions so we can move on with this).
With all this in mind, be unfailingly polite. Expect the same from everybody else in the room. It will just make things go so much quicker and easier. But realize that even small talk while off the record can be heard. Wait to discuss your thoughts and impressions of everything until you’ve left the building.