Several times I have written about depositions questions to be suspected and refused avoided.  I have, for example, written about questions ostensible trying to make sure that the deponent understands questions.  I have suggested that they really tricks to try and lock people into answers when they did not actually understand the question.  

Now I have another one which might come at the end of a deposition.  

Q. “Have you understood all the questions I have asked you?”  

The “Yes” answer should be avoided. 

Instead, the answer should be this, or its equivalent: 

A. “I don’t know. I think so, but I am not certain. One can think one understands something someone else has said, but actually doesn’t.”  For many dependents, a shorter version of the “Quinn Answer” is also appropriate. 

Michael Sean Quinn
Attorney at Law 
Austin Texas