How to Ask a Vague Question
I was in depositions yesterday on a car wreck case. There was a dispute about how the collision occurred. The other side disputed how the responding officer stated the collision happened. Honestly, the other side was not a good historian, was a bit cantankerous and the deposition lasted much longer than is typical in this situation. After his deposition, we took the wife’s deposition and had the following exchange:
Q: You were present for your husband’s deposition and heard everything he said?
A: Yes.
Q: Do you agree with everything your husband said?
A: Good heavens, No.
Q: Let me reprhase that. Regarding how your husband described the car wreck, the speeds, and the position of the vehicles at the time of collision, do you agree with all that?
A: Yes.
Sometimes you have to be more precise. (I typically don’t like compound questions, but I already knew that she didn’t have an opinion that was different than the husband’s).
