When you are on the stand during a deposition, a Bronx employment law attorney cautions you to avoid “closure questions.”
A “closure question” is one designed to end a particular area of testimony. An opposing lawyer will do this so you can never go back and add information that you forgot. Here are examples of some “closure questions”:
- Have you now fully testified to your emotional distress?
- Did your company promise you anything else?
- Have you now described each instance in which you were harassed?
A Bronx employment lawyer offers certain strategic answers to avoid “closure questions”:
- “That’s all I can think of right now.”
- “I am sure I am forgetting every occurrence.”
- “This is everything I can specifically remember at this time.”
- “This is all I remember right now.”
Answering in this manner allows you the opportunity to return to this information later if you recall things that you forgot. However, this method does not give you license to avoid memorizing answers to important questions regarding your case. The opposing counsel will always look for an opportunity to imply that you are making any additional incidents up, so it is always best to prepare to the best of your knowledge.
Here are some other dangers to avoid in your deposition:
- Do not say anything to your lawyer unless you are in a private room. This includes whispering;
- Never tell jokes during a deposition;
- Never demean or slur any group of people because of their race, religion, gender, age, sexual preference, disability or national origin. These people may be on your jury; and
- If you need a break, take one. No need to be physically uncomfortable.
And finally, always tell the truth regarding any questions as to how you are feeling. If you are feeling fine, say so, but if you are tired, nervous or don’t feel well, mention it if asked.
For more information regarding what to say in a deposition, contact a Bronx employment law attorney at the Law Office of Delmas Costin, Jr. at 718-618-0589.