Lawrence M. Berezin, Esquire

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N.J. personal injury lawyer

Depositions                                                                                   

A deposition is another tool in a N.J.personal injury attorney's toolbox. A plaintiff's deposition is generally taken in the conference room of the plaintiff's personal injury lawyer. Plaintiff is seated at a conference table, and her lawyer is present during the entire proceeding.  The defendant's lawyer, and a court reporter are in attendance. The defendant's lawyer will ask you a series of questions, and follow up questions about your case.

Prior to the deposition, a plaintiff is asked to swear or affirm to tell the truth. The court reporter will take down every word uttered by a everyone in the conference room. After the deposition is completed, the court reporter prepares a transcript of everything that was said during the proceedings.

The transcript can be used during the remaining period of discovery process, and at trial of your case. A plaintiff must tell the truth, and his deposition testimony must be consistent with answers to the same or similar questions posed during discovery, or at the trial of the case. For example, if you say the light was green at your deposition; and testify at your trial, in response to the same question, the light was red, you are in a heap of trouble!


Here is an example of the wrong way to use the response, "I don't recall" at a deposition. Observe the Mayor's body language and demeanor. Did his lawyer do a good job preparing him for his deposition? The outcome of the case was that NYC paid $7M to the plaintiffs.

Depositions are important and should be taken seriously. Thorough preparation and practice is
the key to a        successful deposition





                                                                       
These
are some of the areas that a defense attorney covers during the course of an N.J. accident victim's deposition:

  • Your residences for the past 10 years
  • Your educational background
  • Your employment experience
  • The nature of your work.
  • Your version of the accident
  • Your injuries
  • Your treatment
  • Your present complaints (pain and suffering)
  • Your functional impairments
  • The impact of your injuries on your life
  • Your economic los