Okay friends, I have to attend a deposition on the 28th regarding labor and delivery. I'm not going into specifics unless you really need the details.

I was the admitting nurse and turned over care at 0700. The mistakes were made while I was sound asleep at home.

Most of you know that I have legal background, but I've never been on this end of the deposition table, so to speak.

What tips, tricks can you give me to stay calm, cool and collected? I'm really nervous about this even though I did nothing wrong.

The nurse I gave report to is the one who really has to worry.

I assume you will have counsel representing you. Before you answer ANY question give counsel a chance to object or comment. Don't answer immediately. Always take a deep breath to consider your answer.

Yes, I have very good counsel representing me, and the entire hospital for that matter.

It's just that the dep prep was brutal.

I was told that waiting too long to respond can be detrimental.

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Originally Posted by J_9

I was told that waiting too long to respond can be detrimental.

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Too long, yes. If you have been prepped, there should be some question you can answer quickly (like your name, address, job title). But taking a breath shouldn't be considered too long.

Agree with Scott - I would advise a pause before giving ANY answer. If the "other side" is any good you'll be ASKED if you were prepped.

I would let that pause be part of my speaking pattern.

Answer ONLY what is asked, give no other info.

If you are nervous you'll be more on guard; witnesses who take the whole process lightly tend to blather on and on.

I'd also make direct eye contact with the person asking the question. No looking left or right, no shifting, no looking down.

If you don't know or don't remember, say just that.

Will you be questioned involving some other statement you gave, written or oral?

I have never given a statement either written or oral. Thankfully.

Also, the entire event was caught on video tape. I have never seen the tape. Again, thankfully.

Answering a question with a question - are you represented (individually) by counsel; is your liability carrier providing counsel for you?

I am being represented by the hospital's counsel. I'm not being sued, the doctor is, but since my name is on the chart I have to be deposed.

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Originally Posted by JudyKayTee

Agree with Scott - I would advise a pause before giving ANY answer. If the "other side" is any good you'll be ASKED if you were prepped.
...
I'd also make direct eye contact with the person asking the question. No looking left or right, no shifting, no looking down.
...

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"Q: Did you discuss this deposition with anyone else?"
"A: Well, I did discuss it on askmehelpdeski.com"

:D

Remember, you are not a live witness on the witness stand. Thus, unless a video recording of the depo will be presented at trial, your demeanor doesn't really make any difference.

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Originally Posted by JudyKayTee

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Answer ONLY what is asked, give no other info.
...
If you don't know or don't remember, say just that.
...

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Exactly.

Quote:

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Originally Posted by J_9

... I was told that waiting too long to respond can be detrimental.

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And why is that? Is this depo. On video and will the video be shown to the trier of fact?

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Originally Posted by AK lawyer

"Q: Did you discuss this deposition with anyone else?"
"A: Well, I did discuss it on askmehelpdeski.com"

:D

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That's exactly why I did not want to put any details of the case on here. ;)

The dep notice did not state whether it was a video dep. All the deps that I noticed out, years ago, were required to state if it was a video dep. That was in Michigan, not Tennessee.

I did have a dep prep in front of a camera though and was able to watch myself afterward.