A transcript presents as a bound volume of pages, each consisting of 21 double-spaced lines of text. And here is the most important thing-- the spaces between lines of text are uniform. More specifically, the spaces between each line of text do not expand or contract depending on how quickly the deponent responds, or how long the deponent pauses to consider a response.
When the transcript is read, later, at trial or as an exhibit to a motion, the Q&A appears as a constant and consistent cadence of line-space-line-space.
The transcript records only the beginning time of the deposition, and the concluding time. Anyone considering the duration of a deposition could only calculate an average time, on a per question-and-answer basis.
English novelist Mary Anne Evans (writing as "George Eliot") correctly observed:
Blessed is the man who, having nothing to say, abstains from giving in words evidence of the fact.
Bless yourself with silence. In deposition, give the required answer and sit quietly while awaiting the next question. Fight the impulse to fill the silence with more words. At best, you clutter the transcript with needless words (and thus increase the cost to buy a copy of that transcript). At worst, you may contradict, muddle or needlessly embellish on your response in ways that discredit the truth.
In this day of instant gratification, and the constant pull of games, texts, emails, tweets, and other digital consumables, it is very difficult to sit quietly in a room full of people. For how many ticks of a clock could you sit before blurting out "and also....." Your nerves, enthusiasm, or deeply seated convictions about the issues being explored naturally create pressure, a physical swelling in your chest seeking to expel even more words into the silent space that is expanding to receive them.
Fight your instincts. Sit back. Smile. Wait for the next question.
