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I can help you in a number of ways with any case you’re working on that involves work and disability, whether it be medical malpractice, personal injury or workers’ compensation or other litigation. One way I can help you is to design creative questions skillfully as part of the discovery process allowing a much deeper inquiry into the person’s “world of work”.
I’m sure questions you ask a deponent include those to: determine the nature of previous jobs; amount of money making; for whom s/he was working; why employment was terminated; and what qualifications and experience s/he had for the type of work s/he was doing [when injured].
You also question what work the individual has done, if any since the disabling condition, describing job duties; and determining previous employers and earnings. Questions posed to encourage a deponent to detail what it is s/he can and cannot do are important, too.
These are all good questions from you yes, and critical of course (although kinda boring in my humble opinion!). Would it help you to have at your fingertips specifically designed questions (based on evidence to date) at deposition that will produce a much deeper inquiry into the person’s vocational background? I get excited when I think of sooo many other questions you could ask that really get into the meat of the matter!
I’ve heard 90% of malpractice cases are settled before trial, and the deposition often is the turning point in those cases. I’d like to help you prepare questions that will lead to responses offering plenty of material for you to work on your case. My aim is to help you skin that cat in many ways and be ready for the most likely responses from your witness. I hope my help with your deposing techniques is valuable pre-trial as well as if the transcript is used for court.
Plus, please keep in mind, I can definitely help you in more ways to better understand the individual’s disabling condition. A life care plan is perfect for that! Expert witness and testimony services are available as well.
I am here to help you help your client!
Call me ~ Amy Botkin at 515-282-7753 or shoot me an email message at firstname.lastname@example.org and I’ll get back to you. Thank you for reading! Good luck with your legal work.
My professional rehabilitation counseling practice is focused on helping people participate in the world around them, particularly in their own world of work.