1. Tell the truth. Telling the truth is not only morally wise but it will also help you during your deposition and in the possible subsequent trial. If jurors discover that you have lied about one thing, even a small thing, your entire credibility falls apart and winning a trial will be almost impossible.
2. Know your answers to your discovery. Before your deposition will take place, you will submit answers to questions given by the opposing attorney. It is wise to read and know your answers to these questions before you are deposed. This will ensure truthful answers that will sustain your valuable credibility.
3. Remember the defense attorney is assessing how you will look and sound to a jury. Even though you are not in front of a jury, you should act as you were by making sure that every word and gesture you make comes off as calm and believable. Defense attorneys will exploit any chance they get to make you appear unlikable to a jury.
4. Avoid superlatives. Superlative statements are statements in which people explain things in an excessive or exaggerated manner. These are often used by people being deposed to overstate the degree of their injuries and other ailments. Superlatives should be avoided because they will make you appear unlikable and sound unbelievable to a jury.
5. Listen, think...then answer. People frequently are so anxious to answer questions that they will answer them without thinking the question over. This can cause incorrect, untrue answers to be given that could cause contradictions in your testimony or create the impression that you have something to hide. Both of these can be detrimental in front of a jury.
6. Relax. Tensions are high when giving depositions but it is important to just relax. Do not panic or become anxious when difficult questions are asked but simply relax and answer the questions to the best of your ability. If you are relaxed, the jury will find you far more likable and believable. No matter how bad or difficult things may seem, remember the world will not come to an end...later that night you will be in your pajamas, regardless of what happens. We are here to protect you.