Maryland Injury Lawyer Blog

I wrote a blog post for the Trial Lawyers Resource Center on defending your client's deposition that you might find of interest.

The Greatest American Lawyer Blog also makes a point that I did not make that I think is important in the bigger picture of deposition preparation about letting your client be himself/herself. I would add one more big picture point. While many personal injury lawyers will tell clients to fight showing that they are nervous, I think the opposite rule works better: just relax and do not fight being nervous. Defense lawyers to some degree, but particularly juries, are thoughtful consumers looking for "value" as they sit in judgment in personal injury claims. Juries - and even insurance companies - are willing to pay significant compensation to individuals who have been seriously injured in an auto accident or by medical malpractice. But good consumers that they are, jurors want to get something for their money - to help a real person they can relate to who has suffered these injuries. Almost invariably, human beings asked to speak in a formal setting are going be apprehensive. Attorneys, judges and juries understand this. In contracts, unctuous plaintiffs who are smooth as silk from jump street raise red flags. Personal injury plaintiffs are expected to be nervous, particularly in the beginning of their testimony. So our lawyers' advice to clients is to relax, do not worry about it. The truth is what will matter in the end, not whether you are nervous.

For sample depositions, click here.