Missouri Injury Lawyer: Protecting My Client's Interests At Deposition
Depositions are an extremely important part of trial preparations for any attorney. A good deposition will line up the case nicely for trial and a bad deposition can put a lawyer and his client on their heals.
From my standpoint as a plaintiff's personal injury lawyer, deposition goal #1: DO NO HARM. The greatest harm a client can do to a case is to get caught in a lie and most times I find that "lies" are not malicious but rather accidental. A smart insurance company lawyer will turn an innocent failure to recall into an ultimate test for the client's credibility (i.e. "If they lie about one thing, is there anything they won't lie about). Any case that gets evaluated by an insurance adjuster or Missouri jury will ultimately rest on the client's credibility. The lawyer's credibility is second fiddle to that of the client. The importance of the lawyer's credibility/likability is a distant second to the importance to that of our client. 
How can a good lawyer address this issue and solve the problem? Obviously, a good lawyer spends time before the deposition discussing the issue with the client, explaining in very direct terms that: 1) prior medical history or claims history will be uncovered by any competent defense attorney with access to a computer and/or the medical records; 2) guessing will be twisted by the defense attorney to attempt to show a lie; and 3) "I don't know" and "I can't remember" are perfectly good answers when that is the true response.
A good approach is to have clients fill out a claims index so their lawyer can have access to the exact same information as the insurance company. American Insurance Services Group (AISG) is a good company to use but there are others that do the same thing for the same price. For $25, a lawyer can get a full claims history for your client, putting the personal injury lawyer on par with the insurance company in terms of information about prior accidents and claims.
"A lawyer's time and advice are his stock in trade."
