I have heard it said that there are only four good answers a witness can give in a deposition: “Yes,” “No,” “I don’t know,” and “I don’t remember.” I wholeheartedly disagree with this strategy.
Instructing a witness essentially not to provide any real answers to adverse questions can backfire in multiple ways, not the least of which is the fact that this advice essentially lets opposing counsel testify for our witnesses on the record. Think of it this way: When you read a deposition and the answers only confirm or deny the question, the content of that deposition is coming from the question. The question becomes the evidence. The wording of the question comes from the other side.
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