A personal injury deposition gets taken before a trial begins. At the deposition, the lawyers for each side question selected witnesses. A good attorney prepares his or her client for the sorts of questions that could be posed by either of the questioning lawyers.
Some of them would be background questions, such as these:
• Where do you live?
• What is your age?
• What degrees have you earned?
• Where were you working before you got injured?
• Have you had other medical problems in the past?
Some of them would be about the incident that caused the injury
• At what time did the accident take place?
• Where did you become involved in an accident that caused you to become injured? Why had you chosen to be at that particular location?
• What events led up to the accident?
• What happened after that accidental incident? Did you need to get taken to the hospital?
• Did you suffer a great deal of pain, after becoming injured? How frequently did you experience a painful sensation? How long did it last?
• Did your injury keep you from going to work? Did it keep you for taking care of tasks around the house? If so, how did you arrange for those same tasks to be done for you?
Some of the questions would seek information on the treatment being provided to the injured plaintiff.
• What sort of treatment have you been offered?
• Were you told to take a particular medication?
• Did you follow the doctor’s treatment program?
• Did you take the prescribed medication?
You should not expect questions about how the injury was diagnosed. Insurance companies do not like to pay for an expensive diagnostic technique. That can reveal hidden symptoms. Insurers do not want to pay for a procedure that reveals the need for more extensive treatment.
A few of the questions would seek details on the life of the witness, now that many months have passed since the injury-causing incident.
• Has this injury affected your life? Has it forced you to forego certain pleasures, such as a hobby or a type of entertainment?
• Have you been able to return to your job? Can you perform all the job-related tasks that you did before?
• If you were not able to return to your job, did you try to get work elsewhere?
• If you have been looking for another job, what luck have you experienced? Did you manage to get an interview? Did you receive positive feedback from your answers during that interview?
• Do you encounter any problems when carrying out your everyday activities?
• Are you able to drive? If not, what sort of arrangements have you made for getting to a place of employment?