Your Deposition Part Three (3) Conclusion

by Aaron Gartlan

May 9, 2016 | Client Deposition Preparation

How should you prepare for your deposition in your personal injury and accident case?

We are happy you are here for the third (3rd) installment and conclusion of preparing for your deposition. Please, know this is simply a summary and should not serve as a substitute for preparing for your deposition with your attorney. In fact, we actually start the deposition preparation with you at the very first meeting and build on that at each stage of your case. This happens even in cases that are settled without litigation and in cases where you are not required to give a deposition. In fact, in most cases we may not reveal that we are preparing you for your deposition until you have been given a deposition notice. However, the foundation for your deposition is being laid. We welcome your questions and concerns regarding your deposition and case.

Of course, you must be encouraged not to tell a lie, elaborate unnecessarily, volunteer information, speculate, or answer something of which you are not sure. If it somehow becomes necessary to make a guess, estimate or speculate, then you should qualify your answer by saying that “I am not sure” or “I am speculating.”

You need to be familiar with the complaint filed on your behalf and your answers to interrogatories and responses to requests for production from the insurance defense attorney. Again, most of the time, it is best for you to rely primarily on your lawyer for most of this and not be obligated to get into great detail, but you do need to be prepared to articulate the basic factual contentions of your case as you know them to be.

You should be prepared to be cordial and respectful of all of the parties involved and to respect the process. Generally, as Alabama injury lawyers, we have found anger or heightened emotion can be detrimental to the deposition, especially if the emotion is not genuine or is exaggerated. With that in mind, you must be yourself. Sometimes emotion is just natural. At those times, it is good to take a break. If you are tired or have been testifying for more than an hour or so, a break is warranted. Like anything else in life, mistakes are more prone when we are tired or have lost our focus.

Appearance is also vital. The insurance company is going to evaluate that. We advise you to dress comfortably. While it is not necessary to wear a suit or a nice dress unless that is what you are most comfortable in, it is important to dress like you take the deposition seriously. Sunglasses, hats, visors, t-shirts, shorts, tank tops, and short skirts should not be worn. Sometimes, clients must give their depositions in a work uniform.

This is a generalization and an overview of client deposition preparation. The most important thing is to be prepared and for you to represent who they really are in real life.

It is likely you now have a better idea of what the deposition process is and how our firm helps clients prepare for a deposition. It could be you have more questions since sometimes learning more leads to more questions. Please, do not be afraid to ask our legal team for more information.

Injury lawyers David Hogg and Aaron Gartlan take great pride in helping people and families like you and yours stand up to big powerful corporations like insurance companies and welcome messages, calls and visits from people who think their insurance company might be attempting to take advantage of them. When you feel like you have been taken advantage of, especially by a big powerful corporation, naturally, it can seem intimidating and overwhelming and like you do not have a chance to be treated fairly. Our American court system and the right to a trial by jury was created by the people for the people and was designed to give the people a level playing field against big powerful companies like insurance companies.


Aaron Gartlan is a graduate of Troy University and the Thomas Goode Jones School of Law who focuses his practice exclusively on representing those injured by the wrongdoing of others. He is member of the National Trial Lawyers Association’s Top 100 Trial Lawyers, Million Dollar Advocates Forum and Multi-Million Dollar Advocates Forum. In addition to his legal practice, Aaron teaches Business Law as an adjunct instructor at Troy University’s Sorrell College of Business and serves as a field artillery sergeant in the Alabama National Guard.

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