Feeling nervous about giving a deposition is natural. You’ve already been through many difficulties due to your accident, and sitting through an intense series 
of questions can feel intimidating. Knowing what to expect could help you feel more confident, and your personal injury lawyer will help you prepare for your deposition.
Before looking at questions that are likely to be asked during your deposition, understand that the questioning will typically move through three phases.
Personal injury deposition questions will cover:
- Life before your accident
- Facts about the accident
- Life after the accident
Common Personal Injury Deposition Questions
- 1. What illnesses and injuries did you have before the accident?
- 2. Do you suffer from any chronic medical conditions?
- 3. Who is your employer?
- 4. Have you been treated for alcohol or drug addiction?
- 5. Do you have any aliases?
- 6. Have you been convicted of a crime?
- 7. Have you filed a lawsuit for anything before?
- 8. Have you been sued before?
- 9. Did you file an insurance claim for your accident?
- 10. Have you collected workers’ compensation?
- 11. What happened in the moments before your accident?
- 12. Were you intoxicated at the time of the accident?
- 13. What injuries did the accident cause?
- 14. How did you choose your doctors for treatment?
- 15. Have you traveled since the accident?
- 16. How have the accident injuries affected your performance at work?
- 17. Have the injuries impacted your home life?
- 18. Have you completed medical treatments?
During your deposition, your personal injury lawyer will be on guard against questions that violate your rights. Your lawyer may object to questions that infringe on your rights or attorney-client privilege.
Even so, don’t expect to avoid answering many questions. The deposition is a necessary part of your lawsuit. During discovery, both sides are obligated to share information and answer questions truthfully.
Be Truthful and Never Guess
Your personal injury lawyer will emphasize that you must tell the truth. Your deposition will be recorded by text and maybe audio or video. Statements from 
your deposition may be used in court if the case progresses that far. Any inaccuracy in your answers gives the opposing side ammunition to attack your credibility. For this reason, you must know that it is acceptable to say “I don’t know” when you are uncertain of facts or can’t recall them.
“I don’t know” is a far better answer than guessing. Your speculations could serve as evidence of deceitfulness. Facts that contradict your guesses could make jurors think that anything you say is unreliable.
Keep Answers Short and Simple
Whenever possible, constrain your answers to “Yes,” “No,” or “I don’t know.” Of course, many questions will require you to elaborate, but you need to avoid long, rambling answers. You might say something that the other side can interpret in a way negative for your case.
If you don’t understand a question, you have the right to ask for clarification. Don’t try to answer when you are unclear about the exact topic.
Your personal injury lawyer will be at your side and ready to defend you from unfair treatment. Although a deposition is not a comfortable situation, it is a necessary step in the pursuit of compensation, either via an out-of-court settlement or in court. In some cases, the opposing legal team will use your deposition to determine whether to make a settlement offer without a trial. If they pick up on contradicting, conflicting or untrue statements in your deposition, they may decide you’ve said enough to give them a good chance of winning the case before a jury. So again, be truthful but answer all questions succinctly.
A Good Personal Injury Lawyer Will Coach You Through The Deposition Process
In other articles we’ve talked about the importance of finding an experienced personal injury lawyer to represent you in your claim [How to find a personal
injury lawyer] A good lawyer will sit down with you prior to a deposition and prepare you for all likely questions and how to handle them. If you don’t feel adequately prepared ahead of the deposition, tell your lawyer. He or she will work with you to ensure you feel prepared for and comfortable with the process. Often times a lot is at stake, and it’s in their interest too to ensure you are confident and at ease answering difficult questions.
If you’ve been involved in a car accident or have suffered another type of personal injury, contact us at your earliest opportunity. Your initial consultation with Kellum Law Firm is free of charge and free from any obligation to retain our services.
