Coparent Academy Podcast

Episode #182 – How to Prepare for Your Child Custody Deposition
Hosts: Linda VanValkenburg & Ron Gore
Date: October 20, 2025

Episode Overview

This episode is a solo session with co-host Ron Gore, a seasoned family law attorney and co-owner of CoParent Academy. The focus is on demystifying the deposition process in child custody cases. Ron offers practical advice, strategic insight, and step-by-step guidance to help parents prepare for an effective and less stressful deposition experience. The episode is designed to empower listeners with knowledge about expectations, essential preparation steps, and how to conduct themselves during the deposition for the best outcome—always centering the best interests of the children involved.

Key Discussion Points and Insights

1. Tell Your Attorney Everything

(00:13 – 03:30)

• Total Honesty is Crucial: Many clients withhold information from their attorneys due to embarrassment, cost concerns, or assumptions about relevance. Ron stresses that this is a mistake:

  • You’re not trained to know what’s legally relevant—your attorney is.
  • Anything not disclosed up front may come out in deposition anyway, potentially catching your attorney off guard.

  “You have to make sure you tell your attorney everything. If you’re getting into a custody dispute, there’s a very good chance… all of this is going to come to light anyway.”
  – Ron Gore (01:24)

• Issue Spotting: Attorneys can identify issues in your case that might not even occur to you, including problems specific judges tend to focus on.

2. Establish Reasonable Expectations and Stipulations

(03:30 – 06:20)

• Align Your Expectations with Reality: After honest conversations, your attorney can help you recognize which of your expectations are realistic.

  • Adjusting expectations helps you negotiate from a more informed and reasonable position.

• Potential for Stipulations: If you and the other party agree on certain things, you may reach stipulations—taking those off the table and streamlining the deposition.

  • This can save time, money, and avoid unnecessary conflict or embarrassment.

  “Having those reasonable expectations, reaching agreements where possible, is really helpful.”
  – Ron Gore (05:44)

3. Master the Factual Details

(06:20 – 08:27)

• Know Your Own Life Details: Be prepared with facts about:

  • Your child’s daily routine, doctor, dentist, therapist, teachers, grades, etc.
  • Your own work schedule.
  • Your preferences and reasoning regarding custody issues (legal and physical).
  • What is in your child’s best interest.

• Consistency Matters: Think through your positions before the deposition. Changing your stance later opens you up to credibility attacks (impeachment).

  “These are all things that could be asked of you at a deposition. And it’s important that you know your own mind about it before you go in and you get asked under oath.”
  – Ron Gore (07:50)

4. Self-Reflection and Handling Your Own Shortcomings

(08:27 – 10:40)

• Own Your Mistakes: Examine past communications and behavior as a coparent. If you haven’t always acted perfectly, be honest about it.

  • Avoid painting yourself as perfect and the other parent as flawed; it’s unrealistic and unhelpful.
  • Addressing mistakes honestly builds credibility and reassures the court you are willing to improve.

• Prepare for Opposing Issues: Anticipate the other party’s concerns—be ready with thoughtful, well-reasoned responses.

  “Always honesty is the best policy and being able to have some self-reflection about how you’ve done is really important.”
  – Ron Gore (09:52)

5. Demonstrate You’re a Good Witness

(10:40 – 11:58)

• Attitude Matters: A cooperative, informed witness helps the other attorney gauge you’ll be credible on the stand, which can encourage settlements.

• Good Deposition Performance May Prevent Trial: Demonstrating preparation and honesty may push the other party toward agreements rather than prolonging litigation.

  “A strong performance at a deposition can actually save you a lot of time and money by helping the other side know that maybe we need to think about some agreements instead of going to litigation on this.”
  – Ron Gore (11:36)

6. Deposition Decorum and Techniques

(11:58 – 15:05)

a) Listen and Answer Only What’s Asked

• Be as respectful and civil as you would be in front of a judge.
• Listen carefully and answer only the question posed—don’t volunteer extra information.

“You should always be at least as kind and deferential to the person asking you questions as you would be to the judge…”
– Ron Gore (12:09)

b) Yes or No—And When to Elaborate

• If asked yes/no, answer simply unless that isn’t possible, then clarify why.

c) “Don’t Know” vs “Don’t Recall”

• “I don’t know” = Never knew the answer.
• “I don’t recall” = Knew it once, but not now. Be prepared to explain the difference.

d) Take Your Time and Allow for Objections

• Think before answering; this also allows your attorney to object if needed.

e) Don’t Mind-Read the Attorney

• Don’t try to anticipate or outmaneuver the opposing attorney’s line of questions—it distracts you from the question at hand and increases mistakes.

“The cognitive overload is just way too high. So instead, just answer each question truthfully as it comes.”
– Ron Gore (13:41)

f) Use Silence to Your Advantage

• Don’t rush to fill pauses with more information. Attorneys may use silence strategically to prompt you into saying more than you intend.
• Just wait; your job is to answer questions, not to elaborate unprompted.

g) Trust Your Attorney to “Clean Up” Later

• If important context didn’t get shared, rely on your attorney to address it after the other side is done.

Notable Quotes

• “You’re not capable of doing the issue spotting that your attorney is... because of their education and experience, they can make connections to your family law cases that wouldn’t even have crossed your mind.”
  – Ron Gore (01:00)

• “If you change your position later, you’re now creating an environment in which you can be impeached.”
  – Ron Gore (07:54)

• “Silence is a magnificent tool in a deposition. A skilled attorney will typically have some long pauses that create pressure on the witness to fill the silence with information.”
  – Ron Gore (14:18)

• “A deposition is a truly powerful tool in family law cases… If you prepare well, it can create an opportunity to shortcut the litigation process… and ultimately that’s what it’s about—the children’s best interests.”
  – Ron Gore (15:01)

Key Takeaways & Guidance

• Be fully transparent with your attorney—no surprises.
• Educate yourself on every relevant fact about your child’s life and your own circumstances.
• Reflect and be honest about your mistakes; never feign perfection.
• Approach the deposition with calm, focused professionalism: answer only what’s asked, use silence wisely, and rely on your attorney’s guidance for strategy.
• A well-prepared deposition often improves chances for agreement out of court—saving time, money, and stress.

Timestamps for Important Segments

• 00:13 – Importance of telling your attorney everything
• 03:30 – Working with your attorney to clarify issues and expectations
• 05:44 – Reaching agreements/stipulations before deposition
• 06:20 – Knowing key family and personal facts
• 08:27 – Self-reflection: addressing your own mistakes
• 10:40 – The value of being a credible and reasonable witness
• 11:58 – Conduct and best practices for the deposition itself
• 14:18 – The strategic use of silence in depositions
• 15:01 – Deposition as a tool to serve the child’s best interests

This episode provides clear, trustworthy, and actionable guidance for anyone facing a deposition in a child custody dispute. Ron Gore’s expertise shines as he balances legal insight with practical empathy, making it easier for parents to prepare—mentally, emotionally, and factually—for one of the more challenging aspects of family law.