Know what your legal claims are
Go over the details of the case with your attorney and get very familiar with the legal specifics of your case. Know exactly what you are suing for and why, and be clear about the connections between your story and the legal action.
Review your written discovery responses
You will have already been asked many of the same questions on the written discovery questionnaire, and so you can return to those statements as you refine and improve upon your answers. Ask your attorney about any potential weak spots and how you can strengthen you answers.
Look at medical records and other documents from your case
Remind yourself of the details that you might have been too injured to truly take in at the time of the incident. Go over medical records, read accident reports, inspect photos from the scene, and brush up on witness accounts. This evidence is important for you, too, so that you can position your story firmly in the material evidence, and not just in your own memories.
Think about how to tell your story of the accident
Draw on your memories of emotions, what you were thinking and feeling at the time. Try out different ways to emphasize which events. Record yourself practicing, and try to see your mannerisms and inflections as someone watching from the outside would see them.
Consider the impact on your life
Focus not just what happened on the day of the injury, but also on how your life has been affected since it happened. Once the issue of the accident has been affirmed, it’s important to demonstrate how radically your life has been impacted.
Be aware of the defenses that will be raised.
Talk with your personal injury lawyer about the defenses that the opposing party will likely bring against you. Without addressing anything that has yet to be said, try to weave in points that would nullify or minimize objections to your claim.
Be ready to make a good impression
A subtle yet powerful part of the deposition will be how you present yourself during it. Aside from facts and memories and realities of impact, a lot will be deduced and assumed–consciously and unconsciously–from the how
of your deposition, not just the what.
Your personal injury attorney will work with you closely to help you prepare for your deposition. Ask him or her any questions, and listen closely to the insight that your lawyer has to offer on which points will be most important for your case.