Posted on behalf of Harbin & Burnett on Apr 20, 2018 in General Interest
Depositions Part II
What types of questions will be asked at the deposition? Some questions, such as background information, will be asked at virtually all Plaintiff depositions. Other questions are dependent on the type of case. For example, in a case involving an automobile accident, there will be numerous questions regarding the location of the accident, the weather, traffic conditions, etc. Most attorneys follow an outline and ask specific questions in a specific order. Depending upon the deponent's answers, other questions may be asked.
What if I need to take a break during the deposition? It is permissible to ask for a break and generally no one wants the deponent to be uncomfortable. The defense attorney may insist that you answer the question before taking a break. During any break, you will not be allowed to discuss your answers with your attorney
Here are the types of questions generally asked at a worker's compensation claim:
I. Background -- Age, Date of birth, marital status, height, weight, number of children, dominant hand, address, social security number, driver's license number
II. Education -- how far did the deponent go in school, graduation, GED, college, vocational training
III. Military -- service. If yes, ask details such as branch, years of service, type of discharge, etc.
IV. Criminal -- any record? If so, get details
V. Work History -- Jobs worked prior to employment where injured, job duties, whether terminated or voluntarily left
VI. Job with Defendant -- Date hired, job duties, did job change during employment, rate of pay, hours worked, location of job, shift worked, supervisor
This represents just the background questions of a deposition. There will then be questions about the accident, medical treatment, prior injuries, previous claims, current condition and so forth.
This is why it is important to have a lawyer you can prepare you for your deposition and protect your rights during the depositions. A poorly prepared plaintiff can lose the case without even realizing it.