Thanks to Mark Beutler, Miami based Board Certified Labor & Employment Attorney for this cautionary Tip:
As I routinely do, I told my client that, at his deposition, he should be abstemious in offering information, that he had plenty of time to formulate his answers and that he should take as much time as he needs, etc. He followed my directions and did fine at his deposition. I failed to tell him that those rules apply only at his deposition. He testified at trial. On cross examination, he paused for ten seconds more than once to answer a question. His answers to questions were inordinately short and pithy. The jury did not like him.