Jake introduced Lettie [the deponent] to the court reporter, the other lawyers, all names and faces blurred by the sheer number, and he went into a lengthy explanation of the purposes of a deposition. The instructions were fairly simple. Please speak clearly, slowly, and if a question isn’t clear, ask that it be restated. If uncertain, say nothing. He, Jake, would object to anything objectionable, and please answer truthfully because you’re under oath.
The instructions were necessary, and then they were not. Jake, Portia, and Lucien had rehearsed with Lettie for hours in the conference room at the office. She was well prepared, though in a deposition it was impossible to predict what might be discussed. At trial, all testimony must be relevant. Not so in a deposition, which often turned into a prolonged fishing expedition.
Be polite. Be concise. Don’t volunteer. If you don’t know, then you don’t know. Remember the camera [this deposition was video’d] catches everything.
− From John Grisham’s Sycamore Row