Discovery/Depositions

Step 6 of 8 · Our Process

Although jury trials are rare, we prepare every case as though it will go before a jury. Discovery is the stage where both sides exchange information and evidence, and it often determines how much a case is worth.

Common discovery tools

• Written questions (interrogatories) that each side answers under oath.
• Requests for documents, such as medical records, photos, insurance policies and phone records.
• Requests for admission, asking the other side to admit or deny specific facts.
• Subpoenas for records held by hospitals, employers and other third parties.
• Expert witnesses, such as doctors, accident reconstructionists and economists who support your case.

Your deposition

A deposition is your opportunity to tell your story under oath. It usually takes place in a law office or by video, with a court reporter present. The defense lawyer asks questions about the accident, your injuries, your medical history and how your life has changed. We prepare you thoroughly beforehand and sit beside you the entire time.

We also depose the at-fault driver and other witnesses to gather crucial information we use at mediation or trial.

Medical examination by the defense

In many injury cases the defense may request a physical examination by a doctor it chooses, sometimes called an independent medical examination. California law sets limits on these exams, and we make sure your rights are protected.

Deposition tips

• Tell the truth, and listen to each question carefully before answering.
• If you do not know or do not remember, it is fine to say so. Do not guess.
• Answer only the question asked, and ask for clarification if a question is unclear.
• Take your time. You can ask for a break when you need one.