Preparing ahead of time to answer questions commonly asked in personal injury depositions can make your deposition experience a lot less terrifying. Some of the information you will probably be asked includes:
- Places you've lived (with addresses).
- Jobs you've held, wages earned, reasons for leaving and whether leaving was your choice or your employers.
- Every injury and illness you have ever had in your entire life. Expect to recall every hospital visit, the names of every doctor you've ever been to see and all of your medical history. Answer as completely as you can, and add "That is all I remember at this time" or something similar.
- All claims or lawsuits you've been involved in. Any insurance claims, including workers' comp claims, property damage claims, homeowner's claims and injury claims should be disclosed. Any prior lawsuits, including divorces, need to be disclosed, even if they weren't injury-related.
- Your criminal record, if any.
- Details about your accident: where you were going, where you were coming from, where you stopped in between. What route you took, when you left, what you'd been doing prior to leaving, who was with you, how the accident happened, whether you were wearing a seatbelt, what direction you were traveling, whether your turn signal was on, what condition your car was in prior to the collision, what discussion you had with the other drivers and the police.
- Details about your injuries: All the doctors you saw and how your were referred to each doctor, your physical complaints to each doctor, what treatment you received from each doctor, whether the doctors have been paid (and if not, how much is still owing to each of them), what work you've done since your injury, and how many times you've been to treatment.
- Some trick questions to test your memory: what does your doctor look like, what's the color of the car you were a passenger in, who is your family doctor.
- Some trick questions that make you look bad no matter how you answer: Are you feeling better today? Why did you go to see a chiropractor instead of a "real" doctor? Who is paying your doctor? Laws as to whether these questions can be asked vary from state to state, so ask your lawyer.
- Your entire job history, if you're claiming lost wages.
- What you can no longer do after the accident, if you're claiming permanent impairments.
Prior to your deposition, you should discuss your answers to these questions with your lawyer. It's also helpful to review your answers to interrogatories, the accident report, recorded statements, medical bills and records and the legal paperwork you've already filed with the court.
Joe Mohr is a personal injury lawyer practicing in Richmond, Texas. You can reach his web site at www.mohrlaw.com.
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