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
Michael Sean Quinn, PhD, JD, CPCU, Etc

Michael Sean Quinn, PhD, JD, CPCU, Etc. (530)

One of Texas's leading insurance scholars, Michael Sean Quinn is a past chair of the Insurance Section of the State Bar of Texas and has a broad legal practice.

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