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Having your deposition taken is one of the most terrifying parts of personal injury lawsuits for most people. Consider these tips for making your deposition experience less painful:

Dress for your deposition the same way you'd dress for trial. The person asking the questions is sizing you up, trying to figure out how presentable you'll be to a judge or jury.

If you need a break, ask for one. In most states, you're allowed to take a break from questioning when you need one. You should discuss the rules on this with your lawyer before the deposition begins.

Take your time. Think about the question you're asked before answering it. Pause before answering. This is not a timed event.

Don't volunteer any information. The person asking the questions is not your friend and you don't need to help him or her discover other areas to ask you questions about. Say as little as possible. Answer only the question asked and nothing more. Do not be untruthful, but do not add anything extra.

Tell the truth. Assume the person asking the question already knows the answer. Depositions aren't just to discover information, but to lock in testimony or find ways to discredit you at trial. Any inconsistency may burn you later when you're in front of a jury.

Your best possible answers are short ones, such as "Yes," "No," "I don't know," "I don't remember" and "I don't understand your question." It's best to limit your answers to the information that is specifically requested.

Don't volunteer where the person asking the questions can find information. If you don't know the answer to a question, say so. If you're asked where to find the answer, then go ahead and answer truthfully.

Don't argue with the person asking the questions. Your lawyer will be in the room with you and can make any proper legal objections to the questions.

Be very careful about what you say to or discuss with the other lawyer or insurance adjuster (if they're present) during any breaks or before or after the deposition. Anything you say may be asked about later when you are back on the record.

If you're asked a question that calls for you to list things or give a detailed explanation, answer fully. In a personal injury case, you may be asked to describe all your injuries or to list all the activities you can no longer perform after the accident. You should list everything fully, and end your response with something like "and that is all I can think of at this time" or "and that is all I remember at the moment." Otherwise, when you add something later at trial, you might look deceptive or worse.

Be prepared to describe your injuries and pain. What kind of pain do you have? Is it constant, sharp, dull and constant? Does it ever go away? Where does it hurt? On a scale of 1 to 10, how would you rate your pain?

Be wary of the question "Are you feeling better today?" If you answer, "No," it raises the question as to whether all that medical treatment you received was reasonable or necessary. If you answer "Yes," then perhaps your case is only a mild injury and isn't worth a lot of money. Obviously, you are feeling better today (at the deposition) than at the time the firemen were using the "Jaws of Life" to separate your body from your car prior to taking you to the hospital. You should say so. But if you're still hurting, you need to make that clear, too.

Be careful answering questions about times. If you know the exact time something occurred, say so, but be prepared to say how you know the exact time. In all other cases, use the words "approximately" or "about." Otherwise, you may look deceptive later if it turns out that some other witness or document shows a different time.

Don't guess. If you don't know the answer, say so. Don't be ashamed to admit lack of specific knowledge. If you're asked to guess, and your lawyer lets you answer, be sure to state that you're guessing or that the answer is approximate.

Always remember that the person asking the questions isn't your friend, but may have a strong influence on whether the insurance company settles your case or pushes you to trial. So be polite.

Joe Mohr is a personal injury practicing in Richmond, Texas. He can be reached at www.mohrlaw.com.