TRICK QUESTION TO BE TAMED
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.