Perspectives from a reformed civil defense attorney…

About Andrew M. Luther: Before Joining Mr. Short’s firm in 2025, Andrew spent 16 years defending personal injury and medical malpractice cases.

TODAY’S TOPIC: “tell the time, don’t build the clock” at your deposition.

Some dead guy named Bill Shakespeare once said that “brevity is the soul of wit.” I think he might have been onto something and his advice is great when it comes to answering questions at your deposition. When you are deposed, it’s incredibly important to listen to the question being asked and then ONLY provide a short, concise answer to the question. Although this may feel uncomfortable at first and is not how we generally answer questions in a less formal setting, giving a precise answer at your deposition is vital because it forces the attorney taking the deposition to do all the required leg-work to get the information he or she wants. I used to practice with my father on the defense side for years and when we prepped witnesses, we called this the “tell the time, don’t build the clock” answer meaning you should always answer a question as directly as possible (telling the time) without providing unnecessary details (building the clock) that aren’t required to answer the question. If you provide truthful, direct, and concise answers at your deposition, you will have already won half the battle and your deposition will be more impactful.  On the other hand, if you provide unnecessary details when answering a question, this risks additional questions that the attorney taking the deposition may have not even thought of.