Shepherding The Client In A Personal Injury, Wrongful Death And Accident Case: Steps Of Guidance From The Start Of The Battle To The End

by Aaron Gartlan

May 19, 2015 | Client Deposition Preparation

Deposition Part 4

When it comes to preparing for a deposition in a personal injury, wrongful death or accident case, the plaintiff or client does not necessarily need to be burdened with the concern of every detail and possible scenario or potential issue that might arise. In fact, in most instances, it’s better for the client to just rely on their Alabama personal injury lawyers, wrongful death lawyers or accident trial lawyers to deal with those things. That said, the client must be prepared to at least generally talk about the theories of liability in which they have sued under, while leaving all of the ramifications to their Alabama personal injury lawyer, wrongful death lawyer or accident trial lawyers. The last thing you want is for a client to go into their deposition and testify that they do not think the person or company has done anything wrong or that they have no idea why a lawsuit was filed.

As Alabama personal injury lawyers, wrongful death lawyers and accident trial lawyers preparing a client for a deposition, we want the client to be able to thoroughly and in detail describe their personal injuries and damages, which include compensatory damages like out-of-pocket expenses like medical bills, future medical bills, lost wages and loss of earning potential, personal injury, pain and suffering and mental anguish, loss of consortium of a spouse, and punitive damages. This should be genuine and not exaggerated nor minimized. We have witnessed people who greatly exaggerated their personal injuries and damages and people who acted like they were not really injured when they were clearly not able to do what they once could. Both can negatively impact the value of the case. Thus the client must be prepared.

The client should be reminded to listen to the question, as well as for any objection that their Alabama personal injury lawyer, wrongful death lawyer or accident trial lawyer makes, or for their lawyer’s instructions or direction. We also remind our clients that every member of our legal team is there for them. We will not tolerate a client being bullied or being taken advantage of, and we will take a break and talk any time they want.

The plaintiff or client deposition is all about them. The client is being judged, graded and evaluated by the other side, so as their Alabama personal injury lawyer, wrongful death lawyer or accident trial lawyer, we want to make sure the client is as comfortable and prepared as possible to make the best impression possible on the jury, judge and the defendant and their legal team. This takes preparation.

Alabama personal injury lawyers, wrongful death lawyers or accident trial lawyers David Hogg and Aaron Gartlan of the Gartlan Injury Law conclude will conclude this series in part five, so please join us to learn more or give us a call now for a free consultation regarding your case.

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Aaron Gartlan is a graduate of Troy University and the Thomas Goode Jones School of Law who focuses his practice exclusively on representing those injured by the wrongdoing of others. He is member of the National Trial Lawyers Association’s Top 100 Trial Lawyers, Million Dollar Advocates Forum and Multi-Million Dollar Advocates Forum. In addition to his legal practice, Aaron teaches Business Law as an adjunct instructor at Troy University’s Sorrell College of Business and serves as a field artillery sergeant in the Alabama National Guard.

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