HOW SHOULD I PREPARE FOR MY DEPOSITION?
You will meet with your attorney to prepare for your deposition. At that time, he will answer any questions you may have about the deposition and discovery process.
The best deponents take the time to review the facts associated with their cases. In personal injury cases, such as yours, it is
important to review your entire medical and accident history.
You should be able to recall the details of this accident and other
injuries (including car accidents, work injuries and slip and fall
injuries), whether they happened before or after this accident. You should be able to describe how each accident occurred, what parts of your body were injured, what treatment you received from each accident, how long you treated for each
accident, and to what extent, if any, you recovered from each
accident.
Lastly, you were the person injured in this accident. The accident affected your life. No one knows how this accident affected you better than you. You will be asked how this accident affected your life. You must be prepared to give the other attorney details concerning this issue. Be prepared to to tell the other attorney how the injuries affected you in your day to day activities around the house such as sleeping, cleaning, cooking, gardening and taking care of your family. Be prepared to tell the other attorney how the accident affected your ability to do your job. This would include any lifting, sitting, standing, bending, concentrating or other requirements of your job.
Remember, we are attorneys; you know what your job requirements are better than we do. If you are, or were, a student following the accident, be prepared to tell the other attorney how your school was affected by the injuries including having to sit for long periods of time, carry books, concentrate during study hours and walk between classes. Be prepared a tell the other attorney how this accident affected your social life. This includes all activities you do for fun, exercise, health and/or relaxation. Remember, it’s your life. You know how it was affected. Give all the details regarding the accident’s effects on your life. You are not to embellish any facts. You are simply to tell the truth about these issues.