Depositions FULL COLOR PAGE GLOSSY Preparation Session – Generally


HEALING CHIROPRACTIC & REHAB CENTER


We are Hispanics CAR ACCIDENT?


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WORKERS ‘COMPENSATION SPORT INJURIES PERSONAL INJURY:


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Derecha (Rt. 355) al frente de la calle con Gaithersburg Square cerca de Lake Forest Mall


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SILVER SPRING, MD 20903 495 North – salida Hampshire Ave.,28A A la derecha en Elton Road


Cerca de White Oak – Langley Park saw as a result of the collision.


5. If there are any prior injuries to the same body parts injured in the subject collision, get all of the medical reports that relate to them. Without these records, you cannot know whether you will be asserting an aggravation of a pre-existing condition or a new injury.


6. Review any hospital records for evidence of alcohol (ETOH) consumption, or drug abuse, or both. 7. Read the client’s medical problem areas (e.g.,


inconsistencies with other records,


records to search for internal inconsistencies, entries that


require context or explanations). If you don’t have time to do this, review these records with the client during prep session.


8. Google your client. Does your client have a page on Facebook or MySpace? Does he Tweet or blog? Does he use any social networking sites? Find out. Find out if the tortfeasor or any witnesses in the case use social media.


9. If your client is likely to review them, provide him with a copy of his answers to interrogatories and medical records.


16 Trial Reporter / Winter 2011 Damaris Bonilla


1. Work hard to gain the client’s trust. Tell the client stories about past clients whose cases have gone poorly because they were not forthcoming about prior injuries, criminal convictions, prior claims, etc. Explain how the attorney-client privilege works. Explain how you can deal with almost anything that you learn about in advance. Tis method allows you to get your message across without insulting your client.


2. Review whether your client has spoken to anyone about the case.


3. Explain that it is okay for your client to reveal that he met with you, but not to divulge any words that were spoken at the meeting.


4. If the case warrants, consider multiple preparation sessions or videotaping your client, or both. While it may be impractical, some excellent lawyers advocate having a different lawyer cross-examine your client during the prep session.


5. Explain to the client that, if during the deposition, I don’t instruct you not to answer a certain question, it should be answered in the manner we discussed. Tell your client not to argue with opposing counsel or ask of her: “Why do you need to know that?”


6. Review all discovery responses. 7. Try to find out in advance of the deposition if opposing counsel can be expected to act like a bully.6


If so, warn your client about this and explain


that if this occurs you will mix it up with the other lawyer to make it clear that this won’t be tolerated. In short, your client needs to know you have his back. Remind him that a calm demeanor is the best defense, to simply focus on the question and answer he will give, and to ignore the tone with which the questions are asked.


8. Does the client have a criminal history? Research whether it will be admissible. What has the client been doing since he was convicted? How has the client changed his life since that time? You will need answers to these questions to discern how to present him in the most favorable light.


Preparation Regarding


Session Liability Issues


1. Review how the collision happened in as much detail as possible.


2. Explain the difference between a well thought out 6 Te MAJ Listserv is a great resource for vetting opposing counsel.


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