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    It is also vital not to guess during a deposition. Frequently the other lawyer asks questions to which the witness simply does not have the answer. It is important to remember that a deposition is not a multiple choice test. You do not score points by occasionally guessing correctly. Stick to the facts and testify only to that which you personally know.

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    mportant to remember that a deposition is not a multiple choice test. You do not score points by occasionally guessing correctly. Stick to the facts and testify only to that which you personally know.

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    ot score points by occasionally guessing correctly. Stick to the facts and testify only to that which you personally know.

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    Every trial lawyer has seen his or her client’s case reduced in value by an incorrect guess. "I don’t know" is a fair answer if it is true. The time spent preparing for the depositions will ensure that the witness does not have to rely on this answer too often. "I don’t remember" is also fair if you truly don’t remember. Sometimes depos

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