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Pronouns Gone Amok
Evan Schaeffer at The Illinois Trial Practice Weblog makes a good point about pronouns gone amok in depositions.
Evan’s point is that unclear pronouns make it difficult to use the deposition for impeachment at trial.

It's almost impossible to use any single answer for impeachment if the question contains a pronoun:
Q. Were you present when he signed the contract?
A. Yes.
Q. Did you see him sign it?
A. Yes.
If you've to go back three pages to find out who "he" and "him" refers to, it makes the deposition transcript very unmanageable as an impeachment tool.

Those pronouns not only cause problems in trial but also in summary judgment motions. For example, if you are preparing or responding to a statement of undisputed facts, it is easier to rely on deposition testimony that "Mr. Smith" was driving the car, rather an testimony that "he" was driving the car. In the same way, even though it may seem awkward, you should try to refer to the document you are addressing by exhibit number or date or some other identifier. Otherwise, you may end up with testimony that simply refers to "it," as in "did you sign it?"
Evan says that he tries never to use pronouns in depositions, which is probably a good habit. Especially when you are asking questions that you know will find their way into your statement of undisputed facts, make sure that the question and answer can stand alone and do not require reference to other pages to clarify the pronouns.