During your deposition, you can expect the defense attorney to delve into any and all matters relating to the incident that you filed lawsuit on behalf of. You can also expect the defense attorney to go into your history: your medical history, your driving history if it’s an auto accident; those types of things.
Defense attorneys can get into questions about character at certain times. The questions that they ask you are pretty open-ended and we expect the client to answer all of those questions swiftly and honestly.
If we think a question that the defense attorney asks is outside the scope of the case, we can deal with that later. However, at the time of the deposition everything is pretty much open to be discussed and you should be prepared for that.