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Here are some basic deposition guidelines to consider if you are a plaintiff in a personal injury case:

1)  Know the date, time and location of the accident;

2)  Know where and when you sought medical treatment for your injuries;

3)  Do not give flowery answers; keep your answers brief and only answer the question that is asked;

4)  Do not get flustered or impatient with the defense attorney; stay calm, relaxed and confident;

5)  Review your answers to interrogatories well in advance of the deposition;

6)  Be prepared to discuss former accidents you have been involved in in the past and the injuries you sustained in those accidents;

7)  NEVER ask the defense attorney a question;

8)  Remember that everything said is under oath and is being recorded by the stenographer;

9)  Ask the defense attorney to repeat the question if you do not understand a particular question.

10)  RELAX knowing that you have brought this lawsuit and that you are therefore in the driver's seat; it is the defendant who should be nervous, not you.

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