Preparing for Deposition for Motor Vehicle Accident Cases

MVA deposition prep addresses injury-related limitation documentation, pre-existing condition analysis, and the vocational translation of chronic pain.

Checklist

  1. Review medical restrictions documentation
  2. Confirm pre-existing condition analysis
  3. Prepare on chronic pain vocational impact
  4. Review labor market survey if applicable

Questions to ask the expert

  • How did you distinguish accident-related from pre-existing limitations?
  • How did you handle chronic pain in the vocational opinion?
  • What labor market data did you rely on?

Timeline

1-2 preparation sessions.

Required documents

  • Medical records
  • Employment history
  • Labor market survey

Common pitfalls

  • Failing to address pre-existing conditions
  • Overreliance on subjective pain reporting

Frequently Asked Questions

How is chronic pain's vocational impact defended?

With peer-reviewed literature on chronic pain in occupational settings and FCE findings.

References

  1. NHTSAGovernment

Ready to Get Started on motor vehicle accident cases?

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