Relatively new to the practice area, how do you prep for plaintiff depositions when your client is first named?

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Depends what type of insurance lit you’re doing but for med mal:

-review pleadings to understand the claims and players involved, where you fit in
-review all discovery (document exchanges, most importantly medical records, and create a timeline of events to work off)
-review all correspondence (between you and client to see what their remembrance is of events, what plaintiff has revealed if any, any expert reviews done etc)
-internet search - look for any and everything you can find on plaintiff (of course within ethical rules)
-create an outline for your questions. I typically go from mundane to specific. So background info to allegations at issue, then circle back. If there’s codefendants (and good ones) they can clean up your questioning.

Good luck!

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You’re welcome. The first one is always the “hardest” but with practice you will have a general outline going into all depositions that you can tweak as needed.

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Depends on what kind of Insurance litigation you’re doing.

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