Over the years, our firm has learned that telling our clients how their lawsuits will normally unfold and helping them prepare for their depositions are two of our most important tasks. Once we’ve accepted your case, we’ll carefully investigate all the facts, obtain all the pertinent medical records and other documents — and then file the pleadings.
Your deposition is part of the lawsuit stage known as discovery. During this process, we’ll request crucial documents and records from the defendant’s attorney (and those possessed by any insurance company that may be involved). We may also send out questions that require sworn answers to familiarize ourselves with all the defendant’s key information and defenses to your claims. And we may send out requests for admissions. Throughout this lengthy stage that can extend until a trial begins (when no agreeable settlement amount could be reached), both sides will try to learn all they can about the strengths and weaknesses of each other’s cases.
What follows is a broad overview of some of the types of topics we may discuss when we meet with you to prepare you for your deposition. We’ll be sure to answer all your questions in advance so that you will be able to present yourself in the best manner possible – providing honest answers while not providing more information than has been specifically requested.
Steps we take to properly prepare our clients for their depositions
Prior to your arrival, you can be sure that your lawyer will thoroughly read through all your medical records, carefully noting the course of treatment for each injury alleged in your lawsuit. Normally, this will not be the first review since this is also done prior to all attempts to settle your case with opposing counsel. We will have also thoroughly reviewed all still photos or videos that may be pertinent to your case – so we can help refresh your memory about any highly specific details regarding your accident – which may have occurred more than a year prior to the date set for your deposition.
If your accident occurred outdoors, we may review an aerial map of the road intersection (or location on the construction site) with you, so we can be sure you’ll be prepared to answer questions about where all key parties were located just before the accident occurred. We will also go over any photos taken of you while still injured, of your damaged vehicle – or taken of you while you underwent rehabilitative care.
Our goal is not to help you develop “canned” answers to all likely questions posed by the
defendant’s lawyer – but to help you have clear memories of what occurred so you can
easily tell the truth without becoming confused.
While the defendant’s lawyer is trying hard to obtain new, key information about your case from your testimony, s/he is also doing all that’s possible to determine how believable your testimony will be to a possible trial jury at a later date – and if it appears that you’ll be a cooperative witness. Your demeanor and ability to remain calm is important. If there are grounds to object to a question – we will quickly do so. By allowing yourself a brief pause before answering each question, you make this part of our job a bit easier.
We’ll also help you learn how to describe how you were seated in your car when the painful impact occurred – and how each part of your body was then seriously harmed.
It will be crucial for this part of your testimony to remain consistent throughout the case. That’s why we’ll help you review the answers you gave us to turn in as part of the interrogatories (questions) sent to us by the defendant. We’ll also review pertinent “admissions” you may have helped us return to the defendant’s counsel as part of the discovery process.
You can be sure that the defendant’s lawyer will not only later be reviewing your answers – but also how well you presented yourself while being questioned. This is particularly true regarding difficult topics – such as all the pain you originally suffered – or about your remaining physical or psychological injuries. And don’t worry, we’ll follow a basic schedule, so that you get adequate restroom breaks, a chance to make a quick phone call — or meet very briefly with your attorney.
Dressing appropriately — and arriving on time — makes a very positive statement
We normally suggest that you dress for your deposition in a professional manner – much like you would for a job interview. You can also minimize your stress level by planning to arrive at the appointed location (frequently, our law firm conference room) at least 30 minutes early. This will allow you time to ask us any new questions that may have occurred to you – or to look back over key records regarding your injuries.
If you’ve been seriously hurt in an accident caused by another person’s negligence, you need to contact our New York City personal injury law firm. As noted above, we’ll fully investigate the facts of your case and then fight hard to win the maximum compensation available to cover all of your pain and suffering, lost wages, medical expenses and other losses.
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