Preparing for Deposition for Long Term Disability Cases

LTD deposition prep addresses the policy definition, transferable skills application, and administrative-record constraints.

Checklist

  1. Review the exact policy definition applied
  2. Confirm TSA is grounded in documented restrictions
  3. Prepare on any-occupation vs own-occupation distinctions
  4. Document labor market viability evidence

Questions to ask the expert

  • Which policy definition did you apply and why?
  • How did you document labor market viability?
  • How did you handle the administrative record?

Timeline

1-2 preparation sessions.

Required documents

  • Policy
  • Administrative record
  • TSA and LMS documentation

Common pitfalls

  • Confusing own-occupation and any-occupation
  • Thin labor market evidence

Frequently Asked Questions

Can new evidence be introduced at deposition in ERISA cases?

Typically not; the administrative record controls.

References

  1. U.S. DOL ERISAGovernment

Ready to Get Started on long term disability cases?

Contact KWVRS to discuss scope, timing, and the deliverables appropriate to the matter. Plaintiff and defense.