Basics - The Pause

“Sometimes you need to press pause to let everything sink in.”

– Sebastian Vettel, Formula One World Champion 2010–2011

For the basics today I am going to discuss one of the most unnatural things of all that occurs during a good deposition: the pause. I am not referring to a brief pause… I am speaking about a ridiculously long p r e g n a n t pause that lasts from 3 to 5 seconds. Count it out right now: one thousand one, one thousand two, one thousand three, one thousand four, one thousand five. That is a long time. It is a really long time.

Try it out! Ask your friend, spouse or coworker to ask you questions and take that pause before answering the questions. Firstly, you will quickly find that you will have an urge to answer questions faster. Secondly, your questioner will become annoyed and not want to play anymore.

It is so weird, so unnatural, and so annoyingly hard to do. But you must do it. That pause is critical to gathering your thoughts, identifying the question, considering it, and determining the briefest possible truthful answer. Before your deposition, practice this unusual conversation cadence until you are comfortable with it.

Pauses don’t appear in the transcript. Pausing after each question is one of the few things that you can control when you are giving your testimony. It is a crucial step while gathering your thoughts. So use it.