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.

Steve Lombardi
Iowa personal injury, workers' compensation, motorcycle, quadriplegic, paraplegic, brain injury, death
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