Preparing For Questions In Your Personal Injury Deposition

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It is always a good idea to go into a deposition with an idea of what type of questions to expect from the opposing counsel, or you may end up floundering for an answer you were not prepared for and end up hurting your case as a result. Some of the questions thrown your way could include the following:

• Details regarding the accident and resulting injury:
  • What were you doing when the accident happened?
  • Were you obeying all the driving or pedestrian laws at the time of the accident?
  • Where were you injured?
  • Have you filed any insurance claims related to the accident?
• Details regarding any injuries you've sustained:
  • Describe your injuries resulting from the incident.
  • Have you seen a doctor for this injury, and did you receive any treatments?
  • What activities have you been doing since you've been injured?
  • Does your injury prevent you from working or doing other normal activities?
• Do you have a criminal record?
• Please disclose any legal claims and lawsuits you have been involved in before this. (This includes insurance claims, workers compensation claims, and divorces.)
• What is your employment history? (This is especially relevant if you are claiming any lost wages in your personal injury case.)

In addition to the above questions, you could be asked some seemingly unrelated questions. They may ask you to describe witnesses at the scene, or ask you the make or color of a car that was involved. These are perfectly valid questions and are mainly asked to test the reliability of your memory. If you consistently give them varying or untrue answers, they may use it to dispute the validity of your testimony.

Other Preparations

It is always a good idea to prepare the day before your deposition and go over the facts with your own attorney. Walk through the sequence of events and try to recall as much as you can. Write everything down as you remember it. If you don't recall a detail, don't worry about it too much. If questioned about it during your deposition, simply tell them you are not sure or that you cannot remember. This is perfectly fine - no one's memory is infallible, 

It may also help to review all the documents relevant to your case. Go over your medical reports and any police reports with your attorney. This will help you familiarize yourself with the facts of the case and help you be better prepared to answer any questions.

Go over any other questions that may arise with your attorney. Your deposition will go much more smoothly if you know what to expect and you have the answers ready to go.

9 December 2014