“Yes.”
“Just because you understand a question, however, doesn"t mean that you are going to know the answer to every question I ask. If you don"t know, just say that. No one wants you to guess about information you simply don"t have. Understood?”
“Yes.”
“I may ask you about a date or time of some event, and if you don"t recall specifically, I am entitled to your best estimate.”
“Okay.”
“You have in mind the distinction between a guess and a best estimate?”
“Yes, I do.”
“Your attorney may object to questions from time to time to preserve his objections for the record. Unless he instructs you not to answer, you are obligated to answer the question after he puts his objection on the record. Understood?”
“I understand.”
“Great. Any questions about the procedure before we go further?”
