Surprise! They taught us all wrong. We should be doing it so
differently.
We've prepared witnesses for deposition and
cross-examination so many times, we can do it in our sleep.
Listen carefully to the question. Don't try to answer a
question you don't understand.
We've seen it in the training videos. Answer only the
question that's asked, not the question you think they meant to
ask. Don't try to improve on the question.
We've heard it at CLEs and learned it in trial practice
classes. Above all, don't volunteer information. If they
ask you whether you were at Grand Central Station on Tuesday, the
answer is "No"; not "No, I was there on
Wednesday."
We've watched colleagues do this drill with innumerable
clients in countless witness preparation meetings. If
there's even a single word in the question you don't
understand or if there's some ambiguity in the question, just
say "I don't understand the question." Or say
"Can you rephrase the question, please?"
