Prepare yourself. Everything with respect to the matter and the claim is relevant including specific elements of the issue. Your lawyer will have a meeting with you to prepare you for the questioning including bringing up some areas of questions that may be asked in the questioning.
Look over your document and pleadings that you have provided or documents that have been prepared.
Keep calm. Take a few breaths if you feel you are getting angry or upset.
If you normally drink coffee in the morning, have a coffee. Make sure to have a glass of water in front of you (your lawyer will supply same). Make sure you are at ease with your surroundings and that you have anything you may need to keep you focused on the questioning.
If you need a break, ask for one. Whether you are upset or just have to go to the bathroom, you will not be focused on what is being asked.
If you need clarification of a question, ask. Don’t be afraid to ask a number of times if you don’t know what they are getting at. It’s our job as lawyers to make sure our questions are clear enough. Your lawyer may jump in to either help with the question or further ask for clarification.
Take your time with the questions. If you need a minute to put together your thoughts, don’t be afraid. Your lawyer will make sure all the questions are relevant.
Don’t respond with any more than necessary for a question. If you can adequately sum up the answer with one word (such as Yes or No…) do it. However, if you need to explain your answer keep things short and sweet.
If you are asked to undertake to provide a document or any other “undertaking”, do not answer right away. Let your lawyer field the question. The lawyer will make sure you can provide the undertaking and whether it is relevant.