Preparing for Deposition for Personal Injury Cases

PI deposition prep addresses methodology defense, functional capacity application, and labor market data sources.

Checklist

  1. Review TSA and LMS methodology step-by-step
  2. Confirm FCE results application to occupations
  3. Review peer-reviewed references relied upon
  4. Prepare on pre-existing conditions

Questions to ask the expert

  • Walk us through your transferable skills analysis
  • How did you apply the FCE results?
  • What labor market data did you use?

Timeline

2 preparation sessions.

Required documents

  • Expert report
  • FCE
  • Labor market survey documentation

Common pitfalls

  • Weak documentation of labor market survey
  • Overgeneralization of FCE results

Frequently Asked Questions

How specific should the labor market survey be?

Specific to the claimant's geographic area, with employer names and dates.

References

  1. BLS OESGovernment

Ready to Get Started on personal injury cases?

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