Whether you are a plaintiff or a defendant in a Massachusetts personal injury lawsuit, there is a good chance you will be deposed. The American Bar Association provides 10 tips for deponents which I feel can help you if you are facing an impending deposition. Here they are:

1. Tell the truth.
2. Listen to the question. Pause. Think as long as necessary before answering.
3. Don’t pause too long before answering.
4. Make sure you understand the question. Don’t answer unless and until you do.
5. If you don’t understand the questions, say so. Ask the questioner to explain, repeat, or rephrase the questions.
6. Answer clearly and directly.
7. If you don’t know the answer, say “I don’t know.”
8. If you don’t remember the answer, say, “I don’t remember.”
9. Don’t confuse “I don’t know” with “I don’t remember.”
10. Where appropriate, qualify your “I don’t remember” answer. Say something like, “I don’t remember at this moment” or “I don’t remember without looking at” the document in question.