Workers’ Compensation Deposition Preparation and General Overview-Los Angeles workers comp Attorney

Posted by


if you don’t know me already my name is Michael Burgis I’m an attorney, the purpose of this video is to let you know what a deposition is and to go over some general rules for the deposition, keep in mind these are just general rules each rule would I want to gear it more specifically to the fact pattern, but these are general rules let me first I’ll tell you what a deposition is a deposition is simply a question-and-answer session that’s all it is when your deposition is being taken the opposing counsel wants to know what’s going on with your case it is a question and answer session only that’s it let me tell you why your deposition is being taken generally there’s two reasons the first reason is they’re here to make an evaluation of you as a witness here’s the theory if you’re a good witness and we have to take this case to trial a judge is going to like you and likely rule in your favor in which case the defense attorney is going to be more likely to want to settle your case now inversely if you’re a poor witness the judge is going to dislike you likely rule against you and the defense attorney is not going to want to sell your case the defense attorney is going to want to take you to trial because they’re going to think they’re going to get a better outcome it’s very important to be a good witness and a good witness is very easy you generally have to follow two things one be absolutely honest and two do your best to follow the rules I’m going over with you now the other reason why your deposition is being taken is they’re here to get information about your case but it’s important you realize that the person taking the deposition today is the defense attorney they represent the insurance company their interests are adverse to yours the reason why they’re taking your deposition is they’re here to get information to harm your case or information to reduce the value of your case so it’s very important you realize anything you say can and will be used against you so the general rule is the less we say the better now you do have an ethical and legal obligation to do your best to answer the questions they’re asking you but a deposition is not a forum for you to talk tell your story or get your side out we don’t have to get the good facts down for your case here today I know those facts my office will know those facts we’ll argue it in front of a trial judge if we need to like I said a deposition is not a forum for you to talk tell your story or get your side out the less you say the better it’s important you realize that this is a question-and-answer session only when you hear a question before you do anything take a few seconds and think about the question and then respond this is very important this is going to allow a lot of things to happen here today first off I want you to let the defense attorney completely ask their question you’re going to know where they’re going with a lot of these questions you’re going to have a tendency to want to answer the questions before they’ve completely asked them don’t do that let the defense attorney completely ask their question take a few seconds and then respond because if their question changes at the end you could be giving an answer to a different question and it could harm your case the real reason why I want you to take one or two seconds is so that you can really think about the question listen to the question and concisely answer only the question they’re asking you now first major rule of the deposition here today this is going to be a reoccurring theme in this preparation if you’re going to remember one rule from this preparation it’s this rule and that is you need to be absolutely honest that goes for every single question here today try not to think of this as what’s the right answer what’s the wrong answer or how can I wear this the best help my case that is a gray area it’s going to get you into trouble all you have to do is listen the question and answer it honestly now second most important rule of this deposition is that as I want you to concisely answer only the question that’s being asked now I’m going to repeat this because this is where every single one of my clients has problems and in fact my more intelligent clients seem to have more of a problem with this I’m going to add I’m going to want you to answer only the question that’s being asked for instance if I asked you do you know who the President of the United States is now how many of you out there wanted to answer with Obama that wasn’t the question I asked you it wasn’t who is it’s do you know so the correct answer there should have been yes then let me ask well who is the President of the United States and then you can say Obama okay it’s very important now you might think if I if I make the defense attorney have to ask me multiple questions to get to the answer they’re looking for that you’re going to be in the room or in the deposition for a longer period of time that’s actually not the case the more concise you are and when you answer only the question that’s being asked you’re going to be in there for less time okay it’s when you volunteer explain or clarify you get the defense attorney additional information they may have not got on their own which leads them to ask additional questions or guang in attendance like I said that they would have got on their own okay so it’s very important be honest and concisely answer only the question that’s being asked now generally there’s four main responses I want you to try to stick to today yes no I don’t know I don’t remember those are the four main response I want you to stick you try to think those of those are the guns that you’re going to stick to okay now yes-or-no questions it really depends on the defense attorney but sometimes 50 60 70 percent of every question here today can be answered with a yes or no so I want you to treat this as a game when you hear a question after you take a few seconds and think about the question I want you to think can I answer that with a yes or no if you can please do so it’s the most concise way to answer their question you’re only giving them one word and like I said you’re only answering the questions they’re asking you so if you can use it yes or no please do so maybe they ask you about a prior injury for instance let’s say your claim revolves around injury to your back and they ask you prior to sustaining these injuries did you ever complain to a doctor about back pain before now if you think the answer is no but you’re not entirely sure you know maybe when you were very young you fell off a bike and told the doctor somewhere about back pain rather than saying no what I prefer you to do in that situation is say not that I remember the reason being is the defense attorney if they have information indicating that you did have a prior injury and you didn’t recall it if you said not that I remember it’s less damaging to your credibility versus saying no as a general rule you need to assume that defense attorney knows the answers to every single question they’re asking you and for the most part the good ones generally do the reason why they’re asking those questions is they’re trying to catch you lying now in workers compensation claims and in fact in pretty much any claim everything revolves around your veracity or your honesty okay you have to be absolutely honest for every single question like I said assume the defense attorney knows the answers to the questions they’re asking you now if you can use it yes or no please do so and if you think the answer is no but you’re not entirely sure I’d rather you say not that I remember or not that I recall okay now if you can’t answer a question with yes or no such as if they ask describe something I generally want you to answer that as concise and brief as possible my general rule is every question here today can be answered in five words or less now there are a handful of questions it’s okay to say more than five words and I’ll get into those in a second but as a general rule every question you hear today take a few seconds think about it and answer it in five words or less if possible now I’ve said this to some of my clients and I’ve caught them in a deposition taking a very long time to answer questions because they’re trying to get a very complicated sentence down to five words it’s not the end of the world if you use six seven eight words okay that being said I want you to be in a habit of concise brief responses think of it this way every word you’re given here is extra ammo they can use against you so we want to give the defense attorney the least amount of ammo possible so as a general rule try to stick to five words or less if you don’t know or you don’t remember those are perfectly acceptable responses but like I said what I don’t want you to do is say you don’t know where you don’t remember if you really do know or do remember I’m going to give you literally the worst example I’ve seen of this in my entire career I had a deposition of a client they defense attorney asked what her birthday was she said I don’t remember she did this because she hated this defense attorney she didn’t want to give that guy any information now while I appreciate where she’s coming from and not wanting to volunteer information everybody knows that she knows her birthday and she’s lying now the defense attorney is going to want to show that she’s lying in fact she’s lying under oath and they’re going to want to take her to trial it’s very important I want you to be absolutely honest and if you know the answers to the questions you’re going to give them but if you don’t know where you don’t remember perfectly acceptable responses now if you don’t remember an answer they are entitled to your best estimate while they’re entitled to your best estimate they’re not entitled to a guess let me tell you the difference between the two an estimate is anything you have personal knowledge on in most cases you’re dealing with work-related injuries or non work-related injuries but you’re dealing with injuries if they ask you about your pain or symptoms or when you first start noticing these pain or symptoms or when you went to a doctor these are all things that happen to you you have personal knowledge on and you can give you give your best estimate this comes up all the time with dates if you don’t remember an exact date you simply say I don’t remember the exact date if they asked for your best estimate because you have personal knowledge you can do your best to get them an estimate whether it be a week a month a year whatever your best estimate is if you’re going to give me an estimate I do want you to give an indication that you’re giving an estimate and not an exact answer so say approximately or my best estimate is now I don’t want you to guess and that’s something where you have no personal knowledge let me give you an example this if I ask you to tell me the length of the desk that’s in front of me if you’re sitting in front of me and you can look at it you’d have personal knowledge so you can give me your best estimate however if I ask you to tell me the length the desk in my home could you do that you can’t assuming you’ve never been in my house and you haven’t seen it if you give me an answer you just be guessing another example is if I asked you to tell me how much change was in your pocket or money you can give me your best estimate because you put it in there if I ask you to tell me what how much change I have in my pocket can you do so you can’t good now I’m going to ask you a few questions it’s going to be a little bit more difficult because I don’t have you in front of me but I want to give you an example to give you an indication about whether you really know the difference between an estimate and a guess now fast if I asked you do you know how old I am how would you respond your response should be you don’t know if I asked you can you give me your best estimate your answer should actually be now a lot of my clients would have just thrown out in age someone the other day told me I looked 45 I assure you have not 45 some the other day told me I look 25 unless I’m do get Hauser I’m not making it through law school by the time I’m 25 does it matter okay as long as it’s your best estimate you can give it okay but if I asked you do you know how my girlfriend is how do you respond the answer should have been no can you give me your best estimate the answer should be no a lot of my clients will throw out an age usually somewhere close to mine for whatever reason usually a little younger it’s a pure guess okay you have no personal knowledge unless you’ve seen her maybe I have an older girlfriend who paid for all my Law School I wish that were the case I met her in law school and she’s just as much in law school dead as I am okay good so I just want to make sure you understand the difference between an estimate and a guess now another very important role of this deposition is I don’t want you to answer a question you don’t understand very important okay if you answer a question it’ll be presumed that you understood the question and will be stuck with the answer you’ve given so if you don’t understand a question don’t answer it what I want you to do is first ask the defense attorney to repeat the question if they repeat it and you understand it great answer it if they repeat it and you still don’t understand it I want you to ask them to rephrase it or change it around now why the defense attorney is here to get information to hurt your case they’re really not in here to tricking you and answering something you don’t understand so they’ll be more than willing to repeat it or rephrase it so don’t hesitate to ask now earlier I told you I want should be concise five words or less that went for every single question except generally three questions now in the following three questions I’m about to go over with you it’s okay to say more than five words that doesn’t mean it’s okay to speak on the you know give an answer that’s ten minutes long but it’s okay to say more than five words okay I still want you to concisely answer the question but like I said it’s okay to say more than five words the first question is when they ask you what are your current pain or symptoms this is a extremely important question here today let me first off tell you why it’s so important generally in a claim for personal injury or workers sation the way i’m able to obtain a settlement for a client is based on a doctor finding they’ve sustained some sort of permanent disability due to their injuries now if I have a claim and the claim is for the Lobeck and in this deposition the defense attorney asks my client what their current pain or symptoms are if they don’t mention the Lobeck and I later go to argue that there’s some disability to a little bit my clients low back the defense attorney is going to say well why am I going to pay your client for disability to the to the low back in the deposition they didn’t even mention it okay very important when they ask you your current complaints and symptoms we have to get everything out now the word current does not mean this second the word current I want you to treat that as in the last month or so okay so when they ask you your current complaints and symptoms I need you to start with your head work your way down your body just list every body part okay once you’ve listed the body parts then indicate some of the other pain or symptoms that may not be indicated in those body parts things like sleep problems emotional complaints dizziness just things like that so literally it’s just a checklist start with your head work your way down your body let’s say I have an example of somebody who slipped and fell and injured a bunch of their body parts they’re also taking pain medication it’s affected their stomach they’re having sleep problems and they’re having stress depression and anxiety due to the physical pain or symptoms that are in if they’ve asked what their current pain or symptoms are it would go something like this head neck low back left leg sleep problems emotional complaints sexual difficulties that’s it it’s literally a checklist start your with your head work your way down your body just list the body parts another question it’s okay to say more than five words or when they ask you about your job duties this is very important when they ask you about your job duties I don’t want you to just simply tell them your job title I want you to go over briefly all the physical things you did this is very important for a few reasons and it really depends on your type of injury if your injury is a cumulative trauma that’s just as the result of doing your daily job duties over and over again like carpal tunnel due to data entry you work at as a loader and loader and you have a back injury it’s very important you say all the physical things you do because one I want to put the defense attorney I notice how it is you can sustain the cumulative trauma injury irrespective I want the defense attorney to know how physical your job duties are because depending on the level of impairment I may be able to get your permanent disability increased depending on how physical your job is so as a general rule if they ask you about your job duties it’s okay to say more than five words tell them briefly all the physical things that you do the next question it’s okay to say more than five words or if they ask you about your impact of your injuries on something that’s referred to as your activities of daily living let me tell you why this is important in workers compensation partially the basis of the award is based on how your injuries affect you in the things you do every day cooking cleaning grocery shopping running errands personal hygiene just the stuff you do every day so if the defense attorney asks you if your injuries affect you in any of those activities it’s in if the answer is yes you say yes if they ask you to explain it it’s okay to say more than five words I want you to briefly tell them all of the problems you have with all of those activities because I want to put the defense attorney on notice how it is your injuries are affecting you in those activities of daily living now I want you to be very careful though there are two questions that sound very similar but there are different questions and a good defense attorney is going to ask you these questions now one question is are there things that you can do that caused you pain or difficulty now the answer to that question is probably yes and if they ask you what are those activities it’s okay to say more than five words briefly tell them what those activities are I want you to be very concerned if the defense attorney asks you the following question are there things you can no longer do now that you could do before these injuries I want you to be very concerned I generally don’t want you to testify that you can’t do something if it’s even theoretically possible for you to do it and the reason being is as soon as you testify that there’s something you can’t do you make it very easy on the defense attorney to defeat your case because everybody knows life goes on you still have to use those those body parts that are in pain or causing you symptoms but as soon as you testify you can’t do something all the defense attorney has to do is send something to videotape you as soon as they catch you doing what you testified under oath under the penalty of perjury that you can’t do now you’re a liar okay remember and as soon as your credibility is gone in your deposition your case is gone very important my general rule is never say never don’t say don’t don’t say I can’t do something I I want you to be honest but I don’t want you to exaggerate and it’s it’s very difficult let me give you an example of this I had client who injured her shoulder she had been through a lot she had autoscopic surgery on her shoulder so when she was asked are there things you can no longer do she said I can’t do anything at all anymore and I looked at her and then she changed her testimony and said well I can’t move my right arm I saw her drink water with a right arm she opened the door the right arm if I gave her a pen and asked her lift it she’d be able to lift it like I said I generally don’t want you to exaggerate or testify you can’t do something if you can because like I said you just made it very easy on the defense attorney to defeat your case now if they ask you that question are the things you can no longer do the answer should be no or for the most part it’s generally no the reason being is we don’t have to tell them about all the The Painter symptoms you have when you do activities I just want you to be very careful about testifying that you can’t do something if in fact it’s even theoretically possible for you to do so remember that your deposition is based on your memory if you don’t remember an answer like I said indicate that you don’t remember what I don’t want you to do is say I don’t remember but I have that information in my wallet or I have that information in my purse or I have it at home remember that we’re not here to volunteer any information if you don’t know where you don’t remember simply say you don’t know where you don’t remember now if the defense attorney asked you if you have any information at home I want you to be careful about this question as well I generally don’t ever want you to lie here today in fact I don’t want you to lie but what I don’t want you to do is say yes you have information at home let me tell you why let’s say for instance a attorney asked you if you have if you remember the name of a doctor and you don’t remember the name then they’ll ask you do you have that information at home and you think well I got his business card at home so you say yes what’s going to happen is that defense attorney is going to ask to leave a blank in the deposition transcript you later have to get that card producer to my office we then have to produce it to their office and fill in that blank that’s bad enough because that takes time and we’re here to get you benefits as expeditiously as possible and without encumbrance even worse is what happens if you go home and it turns out you don’t have it you thought you had it but it got thrown away well now we’re going to be on the record saying we’re going to produce something that we can’t produce and that does impede your case so as a general rule if they ask you have information at home I don’t want you to lie if you think you have it I merely want you to say I think so maybe or no or I don’t know just not affirmatively yes okay the difference is if you see I think so and you don’t have it we’re not on the hook I’ll say my client thought they had it turns out they don’t sorry so very important we’re not here to produce or volunteer anything the only thing I want you to produce generally during the deposition is a driver’s license or a form of identification you hand that to me or one of my associates they’d review they’d hand it to the defense attorney and it also depends on whether they did a motion to produce various documents that being said the general rule is we’re not here to produce or volunteer anything now let me tell you a little bit about who’s going to be in the room in a deposition you and I are going to be in the room I mean it’s very important that I get this out either me or somebody from my office is going to be in a deposition with you the entire time you have absolutely nothing to worry about if you’re honest here today and do your best to follow the rules you got nothing to worry about furthermore one of us is either myself or an attorney of from my office is going to be in the room with you the entire time what that means if you start to get yourself into trouble we’ll stop the deposition we’ll pull you out and we’ll clear it up so like I said you have absolutely nothing to worry about now because I’m going to be in the room with you or one of my associates I want to make sure I go over a few things with you technically speaking I’m not allowed to coach you during the deposition I’m allowed to prepare my clients for a deposition and if you’ve asked if you’re asked by the attorney if you’ve had a chance to prepare with your attorney the answer is yes if they ask for how long generally I do it for about an hour but give your best proximation on how long we’re in the preparation now while i’m allowed to prepare you for a deposition I’m not allowed to coach you during the deposition now be that as a male I’ll do as much as I can get away with because I’m here to represent you my office is here to represent you now if you see me or one of my associates stick their hand out like that that means stop talking that means you’ve probably already answered the question you’re volunteering too much you might hear your attorneys say is that a yes or a No that means that’s a yes or no question you need to give a yes or no answer your attorney might also say did you understand that question that should be an indication to you that maybe they think you didn’t understand the question what I’d want you to do is ask them to repeat it or rephrase it and listen to it a little bit more closely now that being said myself or another attorney from my office or is technically not allowed to coach you during a deposition if you need to speak to me or the attorney at the deposition you can always say I’d like to speak to my attorney we can take a break go outside and we can talk now why you have the absolute right to do that I want you to be careful I don’t want you to ask to speak to me or your attorney after every question or every other question because then it looks like I’m pulling you out just telling you what to say and you’re coming in and saying it if you need to speak to your attorney feel free to do so technically speaking we can’t do it while I question is pending you’re supposed to answer the question and then I can go outside and have a discussion with you that being said I don’t really care if you need to speak to me at any time please indicate so and we’ll go outside okay now I also want you to be careful if I start to speak in a deposition where one of my attorneys starts to speak in a deposition you need to immediately stop speaking I’m likely going to make some objections where my attorneys are likely going to make objections in the deposition and like I indicated if you’ve already given the answer my objection is irrelevant now for the most part I’d likely have you answered most of the questions but I’m still trying to get my objection noted for the record so I can argue to a judge that the answer is it admissible what I don’t necessarily want you to do is have you not answered a question have a judge later rule you need to answer the question and then bringing you all the way back to an or one or two more questions now that being said if I start to speak you have to stop and you need to wait till I instruct you to answer the question before you do so because there are some questions I will not have you answer now I also don’t want you to be concerned if I get into an argument with the defense attorney or if one of my attorneys gets into an argument with the defense attorney remember that we’re here to represent you your interests are adverse to the defense attorney that can lead me or one of my associates to get into an argument and we get into our share of arguments don’t be concerned doesn’t mean that your deposition is going poorly or that you’re doing bad or your case is bad doesn’t mean that at all it’s just the nature of the adversarial proceedings inversely I don’t want you to be concerned if your attorney is quiet during the deposition don’t think well how come my attorneys not making objections generally you want to take your attorneys silence as a form of comfort that means things are going well that means the defense attorney is asking appropriate questions and you’re answering them appropriately now there’s going to be a defense attorneys sitting across from you very important that you realize this person is not your friend I want you to be polite and respectful to this attorney because remember I want this attorney to like you think you’re a good witness and want to settle your case if you if the defense attorney dislikes you then they’re just going to want to be a little bit more aggressive on your case so it is important that I want you to be polite and respectful but remember we’re not here to clarify argue or explain anything on your case short brief responses only now might drive the defense attorney crazy I don’t care about that I he should know or he or she should know that I’ve instructed my client to concisely answer only the questions were asking you remember that even if we take a break in the deposition I want you to be careful as well don’t volunteer information outside of the break let me give you a rare example of this that I think will be a good example to clarify what I mean I had a two-part deposition the first part of the deposition my client had a full head of hair the second part he had a shaved head defense attorney was very nice we took a little break and he just went to socialize with my client and he said hey what’s with the new hairdo my client then proceeded to say I didn’t honor my father who got diagnosed with cancer now in that little 30 seconds that he volunteered that information we also had a psychological claim for this client and I was arguing that his stress depression and anxiety is attributed due to his work-related injuries we went back on the record and spent about 40 minutes on how his father being diagnosed with cancer affected him emotionally okay so you got to be very careful if you take a break be careful I want you to be playing respectful but don’t volunteer clarify or explain anything remember anything you say or do in this deposition can will be used against you now there’s going to be a court reporter in the depth in the deposition likely sitting to one of the ends of the table they generally have two duties their first duty is they’re going to swear swear you in you know raise your right hand you’re going to take an oath to tell the truth it’s important you realize that your testimony today is under the penalty of perjury what that means is if you lie or mislead today you can be subject to fine or imprisonment so I can’t stress enough be honest now I’ve told this to some of my clients and I’ve caught them lying do not make that mistake it’s not good for your own case if you’re caught lying here and they can prosecute you for perjury so it’s not good for your own penal or pecuniary interests as well so be absolutely honest do not lie now there are other duty is there here to type everything down it’s a very difficult job in fact in my opinion is one of the most difficult jobs out there so it’s very important that a few things are followed one person needs to speak at a time the court reporter can’t type down multiple people talking over each other which is also why I want you to let the defense attorney completely ask their question take one or two seconds and then respond they the court reporter is literally typing down what is verbally said so you must verbally respond to every question it’s human nature to say yes or no by nodding up and down in side to side and you can do so but you must verbally say yes or no because they can’t type down a head nod avoiding him and AH as that’s confusing and difficult for the court reporter as well now sometimes they ask my clients a question things like where does it hurt and my client said oh it hurts right here or it hurts right here and they point to a body part but remember the Court Reporters typing down what is verbally said and they’re typing down it hurts right here so when I go to read that deposition transcript a month later I have no idea where right here is so if you’re going to point to a body part you must verbally describe it now there could also be somebody here from your employer in the room somebody like an HR rep generally speaking it doesn’t happen although it does happen on occasion if they are in the room they generally can’t say or do anything so don’t worry about it and believe me if I see them so much as look at you the wrong way and I think they’re trying to intimidate you I’ll kick them out of the room or stop the deposition ok so generally don’t worry about that now a defense attorney might tell you you’re going to have an opportunity after the deposition to review the deposition transcript the deposition transcript is the booklet that’s typed up of all the questions and answers they’re going to tell you you’re going to have an opportunity to review this and make changes if needed generally I don’t do that I don’t like to make changes in the deposition transcript because it gives the defense attorney to impeach your credibility they’ll say well which one was the truth was he or she lying then or they lying now we’re going to give it our best shot here and if I need to make a change I’ll do it in front of a judge if I need to so as a general rule we’re going to give it our best shot and just as a general recap be honest concisely answer only the questions they’re asking you don’t volunteer clarify or explain anything try to stick to yes or no and if you can answer with the yes or no concise five words or less if you don’t know an answer you don’t remember to answer a perfectly acceptable responses don’t answer a question you don’t understand ask them to repeat it or rephrase it if you need to five words or less for every question unless they ask you about your job duties in which case tell them all the physical things they ask about your current complaints and symptoms start with your head work your way down your body just list those body parts then indicate those things those other pain or symptoms that may not be in Tribble attributed to those body parts if they ask you about those activities of daily living and if you have an impact tell them all the things that you do that caused you pain or difficulty okay we’re going to give it our best shot I don’t make changes if you guys have any questions on preparing for a deposition generally don’t stress if you’re my client one of either myself or an associate attorney will prepare you one hour before the deposition so this is just to help alleviate some stress and give you an idea of the general rules that I want you to follow but keep in mind your attorney is going to prepare you for the deposition an hour before the deposition and go over all the specific nuances that are important to your case now if you’re viewing this and I’m not your attorney when my office doesn’t represent you and you have a claim that’s coming up or your concern about a deposition feel free to give my office a call the number is going to be below you can also check some of my other videos and go over a little bit more of the specifics on your case I have videos that break down permanent disability temporary disability how cases can settle and general overviews like I said we’re here to help okay my slogan is bringing recovery to the injured and I mean that in every sense of the word whether it’s monetarily emotionally or and physically okay so I’m here to get my clients the best medical treatment possible after they get the best medical treatment I want indication from a medical report indicating they’ve sustained the greatest amount of disability that enables me to lock in the greatest amount of compensation for them as well and then of course I want to lock in the greatest amount of future medical care remember our office is here to help the numbers below any questions feel free to call once again my name is Michael Burgess I’m the managing attorney of Michael Burgess and associates the team of attorneys here at MBNA we’re here to help and we’re here to bring recovery to the injured if you have any questions feel free to give us a call the numbers below you can also go to our website and you can go to our links and look at multiple other videos where I break down other sections of the law once again we’re here to help please give us a call we’re standing by

22 comments

  1. Wow! You're awesome. What if one starts a case with a lawyer that's not doing such a great job (in NJ). Can lawyers be changed in the middle of the case?

  2. Thank you for giving us the general overview of what a deposition is and preparation around workers compensation.

  3. Thanks for the vid, I have a question. I have already been to one deposition  a year n half ago. That was my first one. I have another one next month. Why are they having another one on me?

  4. I have a wrongful termination after work related injury at same time . Can it affect my workers comp case negatively ?

  5. I wish you were my lawyer unfortunately I'm in texas and your in california I had a lawyer and he withdrawal after 8 months now they tell me they going to take this – case to a judge I don't know if this is good or bad ? I really don't know what to do

  6. Thanks…I'm a talker I figured the more they knew the better. You made your point don't volunteer, clarify or verify and most importantly..HONESTY. Thanks again great advice!

  7. I have been injured at work, I have a herniated disc on my lower back. I'm on light duty. how ever my employer tries to tell me where I can go during lunch. I am parked at public parking yet they ask me to park 5 blocks away from the job site. Do I have to listen to them on my unpaid lunch? can they fire me for not doing so? thank you

  8. I wished I had seen this just before my depo!!!
    I recently had a deposition and I was in so much pain that I couldn't even think! In the pain question I didn't give all the pain and disfunction I have. Due to nervousness and pain I couldn't pull anything out of my brain! I feel like such an idiot for going brain dead that day!
    Oh well it is what it is. My injuries have completely destroyed my life and I would be answering those question all day. Lol
    THIS ENTIRE INJURY STUFF IS WAY TOO MUCH.!!!! IM SO FRUSTRATED!!

Leave a Reply

Your email address will not be published. Required fields are marked *