In your deposition, don’t try to be the wise guy.

Some clients react with trying to be the wise guy, something that comes off as being “cute”; well don’t. It doesn’t sell well at all.

Things to do during a deposition break.

Some depositions can be pretty boring. Today, via YouTube, we see one thing you can do to make your deposition much less so. YouTube - Dancing hands pa pamericano (baile de manos)

What should I read before my deposition?

Recently I was preparing a client for his deposition and like I've done for 30 years jotted down a quick outline of what he needed to do to prepare for his testimony. Today let's review some of the items that you really need to read/review before raising your right hand to swear to tell the truth.

1. First thing is to go over the Eight Simple Rules and One Simple Question. Then review the tricks defense lawyers play.

2. Review your answers to interrogatories.

3. Photos of the car damage.

4. Read any recorded statements you've given. Not everything is important but some of it certainly will be.

5. Review the Petition and Answer.

6. Review the significant answers to interrogatories by the defendant.

7. Review with your lawyer how the accident happened; visit the accident scene and any review any allegations of fault both against the defendant an that might be leveled at you.

8. We have our clients review the CaseMap Reports for persons, organizations and the time line. The timeline includes a social history, educational history, work history and medical dateline.

Now in some cases you won't do all of this, but in most you will and of course every case is different so in yours there could and probably are other things important to review.

How do I prepare the morning of the deposition?

Rules – 8 Simple Rules and 1 Simple Question – This is a simple concept of rules to be applied when answering deposition questions. I want you to read them and make sure you understand the rules. After you understand the rules then answer the One Simple Question. For the correct answer write to me, I’ll grade your answer and let you know if you answered correctly or not.

Deposition Day - How to talk and what to do with tattoos.

THE TRAMP STAMP: DEAR I GO THERE? O YEAH - A tramp stamp says you’re cheap and easy not worthy of compensation. What you see in your tattoos, conservative jurors, judges, defense lawyers and insurance executives will not see. They would all rather help an injured businesswoman than they would a carnival worker. Prejudiced? You bet, and that’s the nature of this business. Trust me on this one this is about human nature, not what is cool for this generation behind mine. (Get it; behind mine?)

Back to the basics of getting prepared for your deposition

Generally – Dress conservatively not fashionable. It’s not going to impress anyone if you wear the latest Ed Hardy t-shirt with large baggy pants that no one can tell if they are long short pants or short long pants. Think button down collared shirt that is pressed, with black or brown leather shoes that you’ve polished, laces in place, shoes tied, pressed pants with a belt. No big buckle and the more you cover up the better. Guys should be easy. Wash and comb your hair, in fact go out the day before and get haircut so you like nice. Shave that day so you look and ready to go. There’s nothing worse for a lawyer than to have his client show up 15 minutes before the deposition looking like Conan O’Brien or Don King.

DRESSING FOR THE DEPOSITON - GIRLS JUST WANT TO HAVE FUN

This week I’d like to cover depositions from a client’s point of view. Not the really heady stuff but the basics. So Monday we will cover how to dress for ladies. On Tuesday I’ll take on the men and how they should dress. By Wednesday we will again discuss the Eight Simple Rules for how to think about answering questions. Then on Thursday I’ll cover the One Simple Question. And on Friday we will conclude the week with discussing the One Simple Answer. If along the way you have questions then contact me and I’ll answer them as part of what I write. I don’t care what state you’re from, that won’t affect my ability to answer questions in this regard. So generally speaking how do you dress for a deposition?