A deposition is sworn testimony given outside of court — and it can make or break your personal injury case. Insurance defense attorneys are skilled at asking questions designed to undermine your credibility and minimize your damages. Here is what DePaoli Law Team tells every client before their deposition.What Is a Deposition and Why Does It Matter?A deposition is a formal proceeding where you answer questions under oath, with a court reporter transcribing every word. The defense attorney uses depositions to: Lock you into specific facts so you cannot change your story at trial Probe for inconsistencies with your medical records or prior statements Evaluate how you will come across to a jury Discover weaknesses in your case that they can exploit Your attorney will be present and will object to improper questions — but you must still answer most questions. Preparation is everything.The Most Important Deposition Rules Listen carefully to each question — Do not answer a question you did not fully understand. Ask for it to be repeated or clarified. Answer only what is asked — Do not volunteer information. Short, direct answers are almost always better. If you do not know or do not remember, say so — "I don't know" and "I don't remember" are complete answers. Guessing creates problems. Do not guess about what the defense attorney is getting at — Answer the question asked, not the question you think they are building toward. Take your time — There is no time limit. Think before you answer every question. Be consistent with your medical records — Know your records before your deposition. Describe your pain and limitations in detail — Do not minimize for politeness. Describe your worst days honestly. Common Deposition Traps and How to Avoid Them The open-ended timeline — "Tell me everything about the accident." Answer specifically and concisely. You are not required to volunteer every fact you know. The good day trap — "Have there been days when you felt better?" Yes — but describe your overall condition, not cherry-picked good moments. Activities on social media — Defense attorneys search social media before depositions. Anything publicly posted can be used. Pre-existing condition exploration — Be honest about prior injuries but specific about what changed after this accident. Estimates and guesses — Defense attorneys ask for estimates of speed, distance, time. If you do not know, say so. Incorrect estimates become ammunition. Frequently Asked QuestionsDo I have to answer every question at my deposition? +Almost all questions must be answered — your attorney will object to improper questions, but unless instructed not to answer, you must respond. Objections preserve the issue for trial but do not mean you stay silent. DePaoli Law Team prepares every client thoroughly before their deposition.Can the defense attorney use my deposition at trial? +Yes — deposition transcripts can be used at trial to impeach you if your trial testimony differs from your deposition. Consistency between your deposition and trial testimony is critical. DePaoli Law Team reviews your deposition transcript with you before trial. Questions About Your Specific Situation? Call DePaoli Law Team at (916) 962-2896 or submit your case online for a free, confidential evaluation. No fee unless we win. CA Bar #283310.