The injured party (Plaintiff’s) deposition is a most critical part of every personal injury case. This article will discuss how the attorney should best prepare for it.
One of the key elements in every case is that the attorney for the Plaintiff should have all of the injured party’s medical records before he allows his client to be deposed. Hopefully, he or she obtained them earlier in the case, but if treatment is ongoing, new records need to be obtained promptly so they can be reviewed by the attorney and shared with the client.
It’s important to obtain medical records going back for several years before the accident in any serious case, because the insurance defense attorney will always ask about past medical issues that relate to the area of injury in dispute.