“Who is your son’s teacher?” one of the moms at the bus stop asked me this morning.

While my wife has been busy being the PTA president, buying school supplies and clothes, and meeting the teachers, I have been working to pay for my kid’s food, clothing, shelter and future college tuition.

So I tell her, “I don’t know.  You’ll have to ask my wife.”

But I feel guilty about this.  It reminds me of the infamous Woody Allen deposition.  Woody couldn’t name his children’s teachers, favorite pajamas, shoe sizes or best friends.  In giving custody to Mia Farrow, the judge found that Woody was an uninterested parent.

Next time someone asks me, I’m going to know the answer to questions like these.

A deposition is part of the discovery process in a custody trial.  Your spouse’s lawyer gets to ask you a lot of questions, some rude or embarrassing, at his or her office, in front of a stenographer who is taking everything down to be used against you at trial.  You are in the hot seat and it may take all day.

The lawyer has usually done this hundreds of times and knows a lot of tricks, trips and traps.  And the lawyer gets to ask the questions.  You have to answer them.

Here is the number one thing I tell my clients before their deposition.  Repeat the question in the form of a declaration, pause, and finish the sentence.  Put a period at the end of it and then stop talking.  Wait for the next question.

So the lawyer asks, “Where were you on the night of August the 7th of this year?”

You say, “On August the 7th of this year…I was at work.”

This approach has several benefits.  It gives you time to think.  It keeps you focused on the question asked.  It keeps you from talking too much.  It keeps you from guessing.  It keeps you calm.  And it might keep you from saying something that can be used against you at trial.