At Carr & Carr Attorneys, we believe that when you take the time to prepare in advance to answer the questions most commonly asked during personal injury depositions, you can make your deposition experience much less frightening.
Here are a few pieces of information you may be asked to provide as part of your personal injury / auto collision deposition:
Personal Questions & Background History
- Your current address as well as previous addresses where you have lived.
- What you do for a living and detailed information about your previous employment, such as wages earned, reasons for leaving and whether leaving was your decision or whether you were asked to leave.
- This will go so far as to include your entire job history and employment background if you plan on claiming lost wages.
- Your complete educational background – schools you have attended and degrees you have earned.
- Family Information: including marital status, number of previous marriages, how many children you have, who lives with you in your home, etc.
- Plan on detailing every injury and illness you have ever suffered from in your whole life. Expect to be asked to name every time you were seen/treated at a hospital, the names and addresses of every doctor you’ve ever seen and all of your medical history. You will need to answer these questions as completely as you possibly can, and add something like “…that is all I can remember at this time.”
- Plan on listing every lawsuit you’ve been involved in as well as any insurance claim(s) you have made – even those made on your own insurance policies! This will include homeowner’s claims and injury claims as well as any workers’ compensation claims and property damage claims. Any prior lawsuits, including bankruptcies and divorces, need to be disclosed, even if they had no bearing on a personal injury.
- Plan on providing your criminal record, if any.
Questions about the Accident
- You will be asked to provide details about the accident such as where you were headed when it happened, where you were coming from and whether or not you stopped in between and where.
- You will be asked what roads you took, what time you left, what you were doing before you left and whether or not there was anybody with you.
- You will be asked how the accident happened, whether or not you were wearing your seatbelt, what direction you were headed… even whether your turn signal was on or not!
- They will want to know what shape your car was in prior to the collision. Was it new or used, sleek or beat up? They will also ask what, if any, conversations you may have had with the other drivers and the police.
Questions about the Treatment of the Injuries which resulted from your accident:
- You will be asked for details about your injuries: such as every doctor you saw and how you got to that doctor’s office (meaning, were you referred to that doctor by a medical professional or just another person?). With each doctor, they will ask what your complaints were, what treatment you received, and whether the doctor has been paid. If the doctor hasn’t been paid, they will want to know how much you still owe to each doctor. They will also be asking what types of work you have done since the date of your injury, and how many times you’ve been to treatment.
- You may be asked some “trick questions” to test your memory, such as “What does your doctor look like?” or “What color was the car you were driving (or were a passenger in),” and “Who is your family doctor?”
- Some of the questions will make you look bad no matter how you answer, such as: Are you feeling better today? Why did you go to see a chiropractor instead of a “real” doctor? Who is paying your doctor? Laws as to whether these questions can be asked vary from state to state, so ask your lawyer.
- They will also want to know what things you can no longer do after the accident, if you’re claiming permanent impairments.
Before your deposition, make an appointment to discuss your answers to these questions with your attorney at Carr & Carr. It is also wise – and helpful – to review the answers to any interrogatories you’ve already answered, review the accident report, recorded statements, medical bills and records and any other legal paperwork that has been filed with the court.
If you have been injured in an automobile accident, please contact the Oklahoma and Arkansas auto accident lawyers at Carr and Carr. We can meet with you anywhere in Oklahoma and Arkansas.
