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Do's and Don'ts for a Client Preparing for a Divorce Deposition


  1. Prepare thoroughly: Review all relevant documents, including financial records, communication exchanges, and any other pertinent information related to the divorce case.

  2. Understand the process: Familiarize yourself with the deposition process, including what to expect, how to answer questions and the role of your attorney during the deposition.

  3. Be honest: Always tell the truth during the deposition. Lying or being dishonest can severely damage your credibility and negatively impact your case.

  4. Listen carefully: Pay close attention to each question asked during the deposition. Take your time before responding to ensure you understand the question fully.

  5. Keep calm and composed: Maintain your composure throughout the deposition. Remain calm, speak clearly, and avoid becoming defensive or argumentative, regardless of the nature of the questions.

  6. Answer only what is asked: Stick to answering the questions asked during the deposition. Avoid volunteering additional information that is not directly relevant to the question.

  7. Consult with your attorney: If you are unsure about how to answer a question or are uncomfortable with a particular line of questioning, consult with your attorney before responding.

  8. Take breaks if needed: Depositions can be lengthy and intense. If you need a break to collect your thoughts or regain composure, don't hesitate to request one.

  9. Review your testimony: After the deposition, review a transcript of your testimony, if available, to ensure accuracy. Notify your attorney of any errors or clarifications needed.

  10. Follow your attorney's advice: Your attorney is there to guide you through the deposition process. Follow their advice and instructions closely to ensure the best possible outcome for your case.


  1. Don't guess: If you don't know the answer to a question or are unsure, it's okay to say "I don't know" or "I don't recall." Guessing or speculating can lead to inaccuracies in your testimony.

  2. Don't argue with the opposing counsel: Avoid engaging in arguments or debates with the opposing counsel during the deposition. Remain respectful and focus on answering the questions truthfully.

  3. Don't elaborate unnecessarily: Answer the questions succinctly and directly. Avoid providing more information than necessary, as this can potentially open up avenues for further questioning.

  4. Don't lose your temper: Even if the questioning becomes difficult or adversarial, maintain your composure and avoid losing your temper. Getting angry or defensive can harm your credibility.

  5. Don't withhold information: Be forthcoming with information during the deposition. Failing to disclose relevant information can have serious consequences for your case.

  6. Don't discuss the case with others: Avoid discussing the details of the deposition or your testimony with anyone other than your attorney. This includes friends, family members, and colleagues.

  7. Don't bring unnecessary documents: Only bring documents that have been requested by the opposing counsel or agreed upon in advance with your attorney. Bringing unnecessary documents can complicate the deposition process.

  8. Don't interrupt: Allow the opposing counsel to finish asking their questions before responding. Interrupting can disrupt the flow of the deposition and may come across as rude or uncooperative.

  9. Don't be overly emotional: While divorce proceedings can be emotional, try to keep your emotions in check during the deposition. Focus on providing truthful and accurate testimony.

  10. Don't ignore your attorney's advice: Your attorney is there to advocate for you and provide guidance throughout the deposition. Trust their expertise and follow their advice to ensure the best possible outcome for your case.

By adhering to these dos and don'ts, you can better prepare yourself for a divorce deposition and contribute to a successful outcome for your case.


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