How to Prepare for a Georgia Deposition



Your deposition in a court case may be the first time you’ve ever been asked to give legal testimony under oath. Because the questions may be very personal and your answers may be important to your case, and because you’ll be testifying in a room with your Atlanta lawyer and one or more opposing lawyers, a deposition can be intimidating. If you’re giving a deposition in a Georgia civil case, it helps to know ahead of time what to expect.

Before Your Deposition

A deposition is a formal meeting, usually around a conference table in a law office, at which you answer questions under oath. Most questions will be asked by the other party’s lawyer, although your own attorney may occasionally ask you a question to clarify an answer you have given. Under Georgia law, a deposition can’t last more than seven hours. You’ll have to swear to tell the truth, and your answers will be either recorded by a court reporter typing on a special machine, or by an electronic recording device. Your Atlanta attorney will talk to you ahead of time about the type of questions you’re likely to be asked in your particular case, and explain anything that you do not understand.

Generally, you should expect the other party’s lawyer to ask questions about the basic facts of your case, and questions designed to expose any weaknesses they think might exist in your case. These will include information about yourself and details about what happened. If there’s something you find embarrassing that you think might come up at the deposition (such as a bankruptcy, a criminal conviction, a messy divorce, or other situation) tell your lawyer about it ahead of time. Your attorney will help you prepare for your testimony about whatever it is that is embarrassing to you. If your attorney thinks that subject is not an appropriate matter for questions, your attorney will tell you to remain silent if you are asked about it, and at the deposition, your attorney will object to the question and instruct you not to answer.

Even though a deposition isn’t a trial, it is a very serious occasion. Wear conservative clothes (like you would for a job interview), arrive on time, and be on your best behavior. Let the opposing lawyer finish speaking before you answer, don’t argue, and be polite, even if the questions upset you. Remember, the opposing lawyer will take your behavior and appearance at the deposition as an indication of how you would testify and act at trial, and if you act badly, it can result in a less favorable settlement offer from the other side.

During the Deposition: Answering Questions

Before the questions begin, you will be asked to swear an oath to tell the truth. That means you have to answer everything you’re asked truthfully, to the best of your knowledge. A dishonest answer can backfire badly – if you are caught, any settlement offer may be less favorable, and if you forget that you lied and give a different answer at trial, a jury may decide you are not to be trusted about anything and decide against you for that reason alone. Listen carefully to each question, and answer only what is asked.

You should not volunteer information that is not asked for, nor should you chat with the other lawyer or other party (if they are present) during breaks.

When it’s possible, stick with “yes” and “no” answers when asked. And if you don’t know the answer, say so. Do not make up information. You can take time to think about what actually happened before answering.

One important way in which a deposition is not like a trial is that you’re allowed to take breaks. If you need to use the bathroom, talk to your attorney or just get some fresh air, you should ask.

During the Deposition – Answering Hostile or Embarrassing Questions

At a deposition, you can expect some of the other lawyer’s questions to seem hostile or overly personal. Unfortunately, that’s part of the deposition process. It’s the other lawyer’s job to find out everything that might matter to the outcome of the case, both good and bad, personal and impersonal, including information that might be helpful to the other side. But there are rules about what kinds of questions can be asked. Your attorney will object and tell you not to answer if the question breaks the rules. However, you should not be the person who argues with the other lawyer, even if you are asked a question you feel is inappropriate or irrelevant. If your attorney is silent, ask for a break to discuss the question with your attorney.

If you’re facing hostile questions, remember that you’re not being timed. You can and should take a moment to think about your answer. Not only does it help you give the best possible answer, but it prevents the other lawyer from building up momentum. If you’re asked a question that’s really two or more questions, ask the questioner to break it down for you.

Watch out for questions about how you’re feeling. In ordinary conversation, it’s polite to say you’re “fine.” In a deposition, the questioner could use that answer to argue that you are in better health than you actually are. If you are an accident victim and have suffered serious injury from a workplace or car accident Atlanta, for example, be prepared to talk in detail about your injuries and the kinds of pain you feel.

You should also be careful of questions that ask about specific details. For example, the other lawyer might ask you about the exact time an event occurred, or details about other persons who were present. Most people won’t remember those details specifically, especially if they were an accident victim with a serious injury. Unless you can remember the exact time of day something happened, it’s best to say it was “about” or “approximately” the time you remember. If you can remember exactly, expect the other lawyer to ask you why you remember so well.

Finally, sometimes the other lawyer will ask you a question that assumes something untrue. For example, “When did you decide to file a frivolous lawsuit against our client?” Don’t ignore the part of the question that isn’t true; some would take that to mean you agree. Instead, you should point out that you don’t agree with part of the question, and then answer the other part. For example, “I don’t believe that my lawsuit is frivolous, as you suggested. But I can tell you what day we filed it.”

After the Deposition

After the deposition, your attorney will receive a document that contains the record of the questions and your answers as they were recorded. You may have an opportunity to make corrections to your testimony at that time; your attorney can discuss with you whether this is a good idea. If your case does not settle, your attorney will use your deposition to help you prepare to testify at trial. However, a good deposition – where your answers are clear and truthful, and you are polite and prepared — may be very helpful to your attorney in obtaining a favorable settlement in your case.

Help for Georgia Accident Victims

If you’ve been injured in a Georgia accident because of another person’s fault – even if you were also at fault – Atlanta injury lawyers can help you. Gregory M. Stokes and Neil J. Kopitsky have over 30 years of experience helping injured people and their families get justice and payment when they are involved in a car accident, truck accident, motorcycle accident, slip and fall, or workplace accident. They’ve recovered millions of dollars in payments for clients in Atlanta accident, Atlanta wrongful death cases, and Georgia injury or death cases.

Your initial telephone or office consultation is FREE and CONFIDENTIAL, and fees are paid only from what is recovered for you. Please call toll-free at 1-(800) 552-9200 any time, any day, to speak with them. Or, visit their website at www.stokesinjurylawyers.com for more information on how they can help you.

Using the Services of a Concert Ticket Broker



Using The Services Of A Concert Ticket Broker

Normally, when one thinks of New York, one thinks of theater and Broadway. As it has been said, “New York is Broadway, and Broadway is New York” (Susan Stroman, choreographer/director). However, New York is much more than Broadway. It is the center of live entertainment, a city that has more live performances each night than any other city. For people who want to take in a live concert, whether Pop, Rock Pop, or Country Pop concert, or an evening of live Jazz concert, this is the place. Procuring tickets for live concerts of your favorite stars, or for your favorite events, is not going to be easy, without the services of a concert ticket broker.

Whether it is the height of the tourist season, or whether tourism has taken a dip southwards, it is never easy procuring live concert tickets. As a local resident of New York, you have the wherewithal to book your concert tickets well in advance, but the problem starts when you are on a sudden short visit, on business or on a vacation, or . . . if you have important out of town clients clamoring to see a live concert performance. Using the services of a reputed concert ticket broker will be an excellent idea.

Licensed Concert Ticket Broker

When seeking the services of a concert ticket broker, ensure that he is licensed and is a member of the National Association of Ticket Brokers. Such brokers have a reputation to consider, and have to adhere to the code of conduct of the association. They are duty bound to offer the best deals to their patrons, and through the association, all your complaints can be redressed.

A reputed concert ticket broker is duty bound to ensure that all his patrons are satisfied. He will attend to all your ticketing needs, and deal with you professionally and courteously.

The advantage of using a concert ticket broker is that you can lay all your ticketing problems at his door. All you need to do is to tell him your requirements, and he will ensure that you get the seats of your choice. The advantage of using a concert ticket broker is that it is a one stop shop, as far as your concert tickets are concerned. It does not matter whether you are looking for a single concert ticket, or a bunch of them.

A concert ticket broker will charge you more than the original value of the ticket. The charge will be reasonably higher, but then it has to be, to cover the extra cost for procuring your concert tickets for you. The more difficult it is to procure your ticket, the higher the price you will have to dish out.

A concert ticket broker will also offer group discounts, and discounts for special categories, such as for students and for disabled people, etc.

Make your requirements known to the concert ticket broker clearly, and he will go all the way out to get you the best deal possible.

The Right Choice: How to Choose the Right Attorney for your Accident Case



Confused by scores of yellowpage ads for attorneys? Turned off by lawyer TV ads? Don’t know how to find the right attorney for your accident case? Here are some guidelines, which if followed, should make your search easier and also relieve some anxiety.

*Choose an attorney who specializes in personal injury. There are many attorneys who represent personal injury clients in addition to other practice areas, such as divorce, criminal defense or real estate. Choose an attorney whose practice is devoted to personal injury law. The field of personal injury is too complicated for a “generalist” or “part-time” lawyer to master. If you needed surgery on your shoulder, would you rather see a “general” surgeon who performs surgery on many different areas of the body, or a surgeon who only does “shoulder surgery?” Most people would choose the specialist. Don’t take chances with your personal injury claim by hiring a “generalist.”

*Choose an attorney who demonstrates expertise in the field of personal injury law. There are too many different types of the law for any one attorney to claim specialty in multiple areas. No one can do everything well. Most people want to see a specialist. The same is true for lawyers. The field of personal injury law is complex with subtle nuances that could mean the difference between recovering a few hundred dollars versus several thousands of dollars. The attorney you choose should limit his or her practice exclusively to personal injury law. Does the attorney write about personal injury? Has the lawyer lectured or taught other lawyers about personal injury law? If yes, these are good signs that the lawyer is a personal injury specialist.

*Choose an attorney who understands the medicine involved in your case. This is a no-brainer, right? But you would be very surprised at how many attorneys who claim specialty in personal injury have little understanding of the medicine and treatment involved with the client’s injury. For example, take a case involving neck and back injuries. These types of injuries can be difficult to prove in court because spine medicine is extremely complex and the diagnostic imaging may show very little or nothing at all. Yet, this area of medicine has also undergone enormous strides and advances just in the last ten years. There are now new diagnoses in the area of spine medicine that literally did not exist a few years ago, not to mention new treatments and minimally invasive procedures that have been created due to advancements in technology. If you have a neck or back injury claim, you obviously want an attorney who understands spine medicine so proper treatment and diagnoses can easily be pursued or presented to the insurance company in negotiations, or made part of a persuasive presentation to a jury on your behalf. You would be surprised at how few personal injury attorneys really understand this area of medicine yet neck and back injury claims make up the bulk of accident cases that exist in Washington.

*Choose an attorney who actually goes to trial. I know, I know. If you’re like most people who have a claim for injuries, you’d rather not have to go to trial. So why pick an attorney who actually does regularly try injury cases? To understand why this is such an extremely important factor when choosing an attorney you have to understand the business of insurance and why claims are settled. Essentially, the insurance company is in the business of “risk.” That is, it accepts your money with the promise that it will pay you money if you encounter certain risks of harm or damage. The risks are usually low, which is why the insurance company can earn enormous profits. When it comes to paying a claim, the company only pays a “settlement” if there is a “risk” that the company may have to pay more if the person files a lawsuit and goes to trial. Attorneys who regularly win at trial increase the insurance company’s “risk” that it might have to pay much more money if the jury awards more than the last settlement offer. Insurance companies regularly keep lists of the personal injury attorneys who do go to trial. These are the attorneys who can command premium settlement offers compared to attorneys who do not go to trial. Simply put, the insurance company will pay more money to settle a case if there’s a greater chance that the attorney will try the case in court. That is why having an attorney who has a reputation of going to trial can actually increase your chances of avoiding trial.

*Choose an attorney who wins at trial. This goes without saying. An attorney who gets results at trial is the insurance company’s worst nightmare. The insurance company will pay much more money to settle a case if the injured person’s attorney has a winning record than if the attorney does not. Choose an attorney that wins.

*Beware of attorneys who actively solicit you. You should be cautious of attorneys who contact you in writing just after you or a loved one has been injured, maimed or killed in an accident. Most state bar associations have rules against attorney solicitation, or at least have very stringent limitations on this sort of activity. I have no respect for attorneys who feel the need to cross the line by actively soliciting clients right after the accident. If an attorney engages in this sort of unethical behavior it may give some indication how that attorney might perform in your case.

*Be cautious of attorneys who advertise on T.V. or take out big flashy ads in yellow pages or other publications. Did you know that many of the T.V. and yellow page ads for lawyers are paid for by attorneys who have never actually tried a personal injury case in court? In fact, some of these advertisements are created by law firms that have a “policy” of always settling their cases without ever filing a lawsuit! If you were an insurance adjustor who knew that a particular attorney or law firm always settled short of trial, would you ever increase your offer for fear that a jury might award more?

*Understand bar association referral lists. Many local bar associations operate a “referral list” where consumers can get the name of an attorney. Just understand that the lawyer has signed up and paid a fee to be included on the referral list. Some but not all of these referral lists don’t bother to check or verify the attorney’s experience with the type of case that is being referred.

*The likeable lawyer is not enough. There are many people who choose to hire an attorney based solely on whether the attorney is likeable. I know of some very personable and likeable lawyers who claim to do personal injury law, but whom I would never recommend based on their limited experience and expertise. Would you let a likeable surgeon operate on your body if you knew the doctor rarely made it to the operating room? It is important that you like your attorney, or at least respect him or her, but it should not provide the only basis for your hiring decision.

*Choose an attorney who you feel comfortable with. You should feel comfortable with the lawyer and his or her ability to communicate with you. Does the attorney seem credible and trustworthy? Does the attorney explain everything to your satisfaction, or does he explain why an answer to a particular question can’t be given at that time? You should feel comfortable with the lawyer. You should also understand how the two of you will be working together on your case.

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