Here is the setup: You are sitting down at your deposition. You are a little nervous, which is natural. The stenographer is to your left. Your attorney is to your right. Opposing counsel is across from you.
Your attorney has told you to tell the truth, which is excellent advice. After a few preliminary questions, you are asked: “Where did you get your shirt from?” Remembering that you were told to keep it brief, you don’t say: “Oh my gosh, I just snatched it out of my closet and I got it at Target and it was on sale right after Christmas and I only paid $48 for it.”
You respond… “From my closet” or, “From the store.”
Both are good answers. They are truthful and vague, which is ideal. They give the opposing side little new information and don’t reveal anything about you (who doesn’t purchase shirts from a store and put them in their closet?). But one is a much better answer than the other. Which is it?
That’s up to you.
Remember that whatever you say can be followed up on. If you have personal files stored in a file cabinet in your closet, then mentioning your closet might not be the best idea. On the other hand, if you are portraying yourself as someone who is careful with your money, then mentioning the store might force you to later state the name of the trendy La Jolla boutique where you spent $500 on the article of clothing.
Pause before you answer. Think about what you want to talk about with the inevitable follow-up questions. In the above example if you don't have a preference, then the store is a better answer as it does not refer directly to you (many people go to the store, but only a few use your closet).
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