Before every deposition of a client, I advise the witness to always answer deposition questions truthfully in as few words as possible. If a question can be answered “yes” or “no,” then that’s the preferred response. If the client does not know the answer to a question, the answer is “I don’t know.” My second deposition of a client pet peeve is: Clients who resist saying “I don’t know” in response to a question. There is nothing wrong with saying these three simple words. Nobody knows everything. A witness who has an answer to every question in the book is usually not telling the truth and is incredible. The person who admits to not knowing the answer to every singe a question comes across as credible.