A lot of work goes into the deposition of the Plaintiff in a given personal injury case. When I am doing defense work, I spend a lot of time (usually after I’ve left the office) doing work in preparation for the Plaintiff’s deposition because there is a chance that I can make or break the opponent’s case with this deposition.
So as Defense counsel, when I have a Plaintiff’s deposition to prepare for as a lot goes into it, such as:
(1) Review and analyze pleadings, Plaintiff’s Answer’s to Interrogatories, Plaintiff’s produced documents, Plaintiff’s statement to the insurance company, 18 inches of Plaintiff’s medical records in their glorious illegibility, the claim’s handler’s file, the client statement, the incident report, the private investigator’s report.Then I fuss, fidget, review, toy with and just go over it again until the time is present for the deposition.
(2) Discuss strategic plan with Partner
(3) Outline my deposition strategy.
(4) Re-review key documents once more.
(5) Show up at deposition
However, when I have a Plaintiff’s deposition to go, as Plaintiff’s counsel, the preparation and strategy is a lot different:
(1) Show up*There are advantages to both sides. I’ll let you decide which one is for you.
*Sobriety preferred, but not required.