Depositions are key events in any lawsuit.  The Opposing Counsel has the freedom to ask questions that lead to admissible evidence or questions which are reasonably calculated to lead to admissible evidence.  That standard allows a broad range of questions.  Most plaintiff employees are understandably nervous about being deposed regarding their case. 

Some plaintiffs, for example, think they must remember every date, every statement and every key detail.  The human memory does not work like that.  No one remembers every date on which a discriminatory or suspicious act occurred.  But, yes, every employee who files suit should recall in general terms when an even occurred.  Most, if not all of my clients, for example, can recall that they were turned down for time off for Christmas, or that they were denied a requested accommodation a few weeks after July Fourth.  Most of us can recall significant events in our lives in relation to some holiday or time of the year.  if a sequence of events is important to you, then you will surely recall such details.  

Many witnesses, parties or not, will respond with an "I don’t know" or two during their deposition.  But, if the witness tosses out an "I don’t know" too frequently, then their testimony will receive little credit from the judge and jury.  Russ Cawyer at Texas Employment Law Update talks about plaintiffs who do not recall enough.  See his post.  I agree completely.  This truism applies to any witness.  Many managers fail to recall key details.  Once, I counted up the number of "I don’t knows" by one manager during his deposition and argued he did not merit credibility from the court.  He responded to my questions with a "don’t know"  some 20 times in a one hour deposition.  If one side remembers very little and the other side claims to remember very many details, who will sound more credible?  Russ is right, credibility wins trials.