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I’m preparing to take a deposition tomorrow morning in Manchester, New Hampshire, at a large law firm. When I visit these places I’m always thankful I don’t have their over-head. No wonder they charge their clients so much. I’m a commission guy. I get paid a % of what I recover. It’s a win-win.

Anyway, a deposition is a statement under oath. A lawyer asks the witness questions. The stenographer records the questions and answers. It is a very important part of a law suit. It is part of what is called ‘discovery” where a party is able to find out something more about a claim or defense.

As an injury lawyer, I tell my clients that something more happens at a deposition, something far more important than mere discovery of facts. This is probably the other lawyer’s first real life look at you, and the first communication with you. It is an incredibly important event. There is a good chance the person paying the bill, the insurance adjuster, will be there too.

But, there is no need to fear. If a client can just be his or herself, and not try to impress or put-on, a resounding message will be sent to the opposition. It will be a message that this injury victim is powerful because he or she will be liked by the jury. Nothing more important can be accomplished at a deposition. Mastery of the facts and having a super-human memory will mean little if it is done with arrogance.

It is far better to screw up a deposition in all technical aspects, and be likable, than vice-versa.

Being REAL is the key. Insurance companies can’t handle real. It frightens them. It knows all too well that an injury victim who is “real”, coupled with an injury lawyer who is “real” is the most formidable of adversaries. Juries like and can relate to “real” people. This always makes the potential for a good jury verdict.

I tell my clients to be themselves— and this is always good advice.

We at Donahue Law are based in Keene,N.H., but handle in jury cases all over New Hampshire, and across the country.

It costs nothing to talk with me and I don’t get paid until you win.

Keep your strength.

Charlie Donahue, personal injury attorney

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