There’s nothing worse that getting caught unprepared for a deposition, which is why when your litigator tells you to prepare, you ought to listen. Naturally, the specifics will vary wildly depending on the nature of your case, but you need to familiarize yourself with the deposition questions you’re most likely to come up against and know how to answer them with as much certainty as possible.
Here’s a list of basic information that deposition questions will likely probe to help you get started. Keep in mind that surface answers may not be specific enough, so it’s best to be able to answer them thoroughly:
Where have you lived?
What is your past employment history? (this will likely include details about leaving vs. getting fired)
A lifelong history/breakdown of injuries and illnesses.
Any instances of past litigation, i.e., insurance claims, property damage, injuries, etc.
Do you have a criminal record on file?
Were you in an accident? If your case involves an accident, make sure you’re clear on all the details — vagueness comes across badly. Know as much about your role in the accident as is possible. If your deposition is about a car wreck, know what direction you were heading in, speed you were traveling, why you did before leaving, etc.
Were you injured? Be ready to list all the doctors you’ve seen in relation to injuries, how you were referred to them, any treatment you’ve received, how much you owe them if you haven’t paid, whether the injury has kept you out of work (and how, exactly).
There will likely be some questions to test the effectiveness of your memory, like details about your doctor, details about your family or your car.
Litigators will try and make you look bad with trick questions – talk with your lawyer ahead of time about what to expect and what’s out of bounds.
Naturally. knowing how to do a deposition will depend on the details and nature of your case. This is a basic list, geared toward personal injury cases. Also, it’s quite possible that you will end up in a video deposition, especially if you’re not located where the case is being investigated. Don’t let that confuse or intimidate you; your lawyer can help with video deposition tips. In fact, video deposition services can ease the tension of being in a room with aggressive litigators.
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