How should a personal injury lawyer prepare his or her client for a deposition?
A deposition is testimony under oath. It's the first time the insurance attorney actually meets the person injured. He will make a report back to the insurer both of your testimony but also of his impressions of how a jury will think of you.
The attorney needs to make sure he meets with you a day or two before the deposition and takes the time to prepare you for your testimony. He should have all your past medical records and employment records. If he doesn't have them yet he needs to postpone your depo until he has them.
He should instruct you to dress nicely as your impression on the defense lawyer is critical. He should tell you to be respectful and answer questions courteously even if provoked. If you don't know the answer, the attorney should tell you not to guess.
Over a 2-4 hour period, your attorney should review the police report with you, all of your past and accident related medical records as well as your entire employment history.
He should ask you to think about and be ready to answer questions about how your injury affects your activities of daily life.
He should discuss the location and frequency and severity of your pain in every area of your body.
He should go over any past injuries or diseases you have had as well as any prior accidents you might have had.
He will explore in great detail how. The injury you have affects you, your family and your friends.
He will want to know what you can't do at all since you were injured or what you do less frequently now than before.
If your attorney spends a good deal of time preparing you for your deposition, it will put you in a good place likely to achieve maximum value on your personal injury lawsuit.