Any California trial litigation attorney can tell you, whether he or she practices in Indian Wells, Palm Springs or Palm Desert, San Diego, California, Orange County, CA, La Jolla, Del Mar, Laguna Beach, Newport Beach, Corona del Mar, Huntington Beach, Irvine, Santa Ana, Irvine, Ventura, Santa Barbara and San Luis Obispo, Ontario, Rancho Cucamonga, Temecula, Riverside, San Bernardino, the Coachella Valley, CA, La Quinta, Indio, Yucca Valley, or Joshua Tree, depositions can make or break your case. A good defense attorney can make even the calmest deponent nervous. And then there are some deponents who can drive a litigation lawyer nuts.

Many times, clients want to know how to answer deposition questions. First of all, I tell my clients to answer truthfully. Then I advise clients not to watch how politicians answer questions. This is what can happen if a client ignores that advice.

"You said to the policeman investigating the scene of the accident that you weren't wearing a seat belt yet today you state that you were wearing one," the defense attorney stated to my client.

My client smiled sweetly at the news commentator, just like Sarah Palin did to Charles Gibson in her first television interview.

"Would you care to explain this discrepancy?" the attorney asked. The attorney had introduced himself as Charles Johnson.

"Well, Charlie, I believe everyone should wear seat belts when they are in a car.

"Okay, but can you explain why you told the police officer at the scene that you weren't wearing a seat belt?"

My client smiled sweetly again, giving the attorney her best impression of a political candidate.

"Charles, I believe in a woman's choice, however I feel even more strongly about the sanctity of life."

"You're not going to answer the question, is that what you're saying?" the attorney asked, looking over his own eyeglasses.

"Well, I really think that there are much bigger issues to discuss," the client answered, putting the attorney on the defensive.

"Don't you think it's important for us to know if what you say now is different from what you said earlier?"

My client looked directly at the attorney. "Charlie, I believe what is important here is that your client ran a red light."

"Lets move on to the fact that you claim you never had a back injury before this accident.. How do you reconcile that with your treatment for back pain prior to this accident?"

"Charlie, as you know, you can have a visit to a doctor without it being for an injury. I have to say this type of questioning borders on being sexist."

"Did you or didn't you have treatment for a back condition prior to this accident?" the attorney said, raising his voice.

"It's not what you go to for a doctor, it's what the doctor does for you, Charles, and when you realize that women are different from men, you'll learn that women doctors do things differently than male doctors."

"You're refusing to answer my questions."

"I've answered all of your questions," my client said.

"No," the attorney said. "All you've done is give me stock answers to the questions you want me to give and not answer the questions I'm asking." The opposing attorney turned to me and realized I hadn't made a single objection.

"Please, ask me your question, and I'll be as honest as I can."

"Is it true that this has been your third accident this year and that each time you've been rear ended."

My client smiled and the attorney asking the questions knew he would not be getting an answer to this one that he could use.

"I believe that God has a plan for each of us and sometimes he tests our resolve."

"That's your answer?" the attorney asked. "You might as well be speaking in tongues right now."

"God has a plan for all of us, Charles, even for you," my client said.

"If it's to drive us nuts, it's working," the attorney said. "I'll give you one last chance to answer a question. Did you cause this accident?"

"Charles, what may be interpreted as a cause could sometimes be otherwise viewed as simply trying to avoid the, you know, impossibly difficult or, trying to prevent that kind of thing, then again, even when you are driving carefully, these accidents...and this could be viewed as one of those situations. Does that answer your question?"

Two hours later when the deposition had ended, the attorney was looking frazzled.

"How did I do?" my client asked me after the deposition was over.

I smiled sweetly like any good politician. "It's not how well you did," I said. "It's how many psychiatric treatments that attorney is going to need before he is able to attempt another deposition."

Note - In California, refusing to answer questions can lead to having a motion filed against the party who refuses to answer deposition questions, and an imposition of a fine against the deponent or attorney who abuses the discovery process. Sadly, many deponents and attorneys in California abuse the deposition process when they think the other party's attorney won't take the time to file a motion to compel. An attempt to evade questions as a politician often does, or answering with stock answers instead of providing answers responsive to the questions is clearly improper. And politicians who answer questions in this manner are not setting a good example. On the other hand, some of Sarah Palin's answers to questions put to her by Katie Couric, similar to this deponent's last answer, were so incomprehensible it is hard to know how a judge might view answers such as hers.

Sebastian Gibson graduated cum laude at UCLA in 1972 and received two law degrees in the U.S. and the U.K., graduating with an LL.B. magna cum laude from University College, Cardiff in Wales and a J.D. from the University of San Diego School of Law in Southern California.

The Sebastian Gibson Law Firm serves all of San Diego, Orange County, Palm Springs and Palm Desert, the Coastal Cities from La Jolla and Del Mar to Laguna Beach, Newport Beach, Irvine, Santa Ana and Irvine and up to Ventura, Santa Barbara and San Luis Obispo. We also serve the Inland Empire cities of Ontario, Rancho Cucamonga, Temecula, Riverside and San Bernardino and all the cities in the Coachella Valley

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