Here are some basic deposition guidelines to consider if you are a plaintiff in a personal injury case:
1) Know the date, time and location of the accident;
2) Know where and when you sought medical treatment for your injuries;
3) Do not give flowery answers; keep your answers brief and only answer the question that is asked;
4) Do not get flustered or impatient with the defense attorney; stay calm, relaxed and confident;
5) Review your answers to interrogatories well in advance of the deposition;
6) Be prepared to discuss former accidents you have been involved in in the past and the injuries you sustained in those accidents;
7) NEVER ask the defense attorney a question;
8) Remember that everything said is under oath and is being recorded by the stenographer;
9) Ask the defense attorney to repeat the question if you do not understand a particular question.
10) RELAX knowing that you have brought this lawsuit and that you are therefore in the driver's seat; it is the defendant who should be nervous, not you.