This California Civil Deposition Admonitions document clearly lays out the necessary
admonitions that should be given to the deponent at the beginning of a deposition. It
informs the deponent how the deposition will be conducted and instructs the deponent
how to respond to the attorney's questions. These admonitions assist in breaking the
initial tension that exists at a deposition and gets the deponent speaking. Such
admonitions can help the deposition run smoothly and efficiently.
California Civil Deposition Admonitions
Deposition of _____________ [Instructions: insert name of deponent]:
1. Introduction - Before we begin, I would like to go over a few ground rules that should make
this deposition proceed efficiently.
2. Under oath - Even though we are in informal surroundings, the oath you have just taken is
the same as if we were in a court of law and carries with it all the same penalties of perjury.
Do you understand that?
3. Audible responses - Verbal Responses are needed for clear record. Head shaking and ‘uh-
uhs’ are useless. You need to state “yes” or “no” or “I don’t know.”
4. Assumption of understanding - If you respond to a question, I will assume that you
understood the question.
5. Clean record - The court reporter is recording everything we say. In order to keep a clean
record, it is important that we do not speak over one another. As such, you must wait to
respond until I am done asking the question, and I will wait until you are done answering
before I ask the next question. Okay?
6. Estimates, not guesses - During the deposition, you will be asked to provide me with
estimates. I ask, though, that you do not speculate or guess. Do you understand the
difference between estimating and guessing?
7. When the deposition is over, the record will be turned into a booklet. You will receive the
booklet and be given the chance to review the transcript. During your review, you may make
changes to the transcript, if you believe them to be needed. If you do make material changes,
I warn you that I am able to comment upon the change should this proceed to trial. This
could hurt your credibility, so it is important that you give you best testimony now.
8. Finally, this is not a marathon. If at any time you would like a break, that is fine. If there is a
question pending, though, I ask that you respond before we take a break.
9. Is there any reason why this deposition should not go forward at this time? Have you taken
any medication that would affect your testimony?
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