Caladium, please do not be stressed by this discussion, and see that I clearly put in that sentence that you had no ill intent and I guess I would add that I was writing about depositions in general and do not believe that you are coached personally. My concern was where the questions and answers were headed...since more questions were still being posed after we had exhausted our resevoir of collective, healthy answers. I can totally sympathize with your fear of more depositions.

Just fyi, I don't agree with printing out ANYONE's posts and giving them to anyone...we've had this discussion before, frankly, that the posts and information on them need to "stay here" when there was the topic of a depression poll for use in your legal case. And my whole point is that it would do anyone absolutely no good to try to involve our forum posts / opinions / symptoms in one's own case, to show to one's own doctor, or use in a deposition, as the focus of your treatment should be on your particular symptoms as well as the relevant point of your case is your own unique disabilities. My posts, or Anne's, simply are not relevant. Having a "template" prepared by someone here would actually, possibly, get a person into a tough corner perhaps, where "appearances" DO matter.

I do not practice right now - at all - but I just remembered a tactic that some attorneys use to catch a deponent where they will ask the deponent questions about who they "prepared with" for the deposition, or if they have a little list or paper with them, "who created that document", etc. This would sometimes result in some pretty ugly answers - such as, I got this list from my friend who wanted to help me...or I prepared with my friends who also had depositions...or my attorney and I spent two days preparing (from which an appearance of coaching can be drawn from such an unreasonable amount of time being the key issue there.) I can't remember all of the tricks, but yes, now they are coming back to me, and again that's where and why it's so important to just talk to your attorney - they will know the boundaries of appropriateness - and confirms for me, that my concerns over these questions and where we were headed as a group was correct. Be careful.

But, don't freak out. The kind of fraud that a deposition is supposed to uncover involve issues where there are previous illnesses that matter, and they haven't been disclosed; if there are other business or recreational activities which have a bearing on the illness and those have not been disclosed; or describing one's illness in a way that is TOTALLY contradicted by what that person does everyday openly and in a really shocking fashion - a person who says they are bedridden but then they go off on safari in the bush and there are films of this person climbing Mt. Everest; or if the person someone is saying they are, they aren't! I call this BIG fraud - the kind where you can't believe someone has kept it a secret - the kind where you are shocked. Each case has a few sensitive points, but that's where the attorney comes in to help counsel - not coach to supplant your testimony with his - you to know how best you can handle it, bearing in mind what is truthful. So for the vast majority of us, we get all nervous and worried when in fact we do very well in the deposition because we are honestly and accurately reflecting our disability / illness.

So you see it isn't so much that you "get everything in", as much as what you do say, is accurate and doesn't contradict something else you've said.

God bless you all in your legal matters regarding your TOS and other diagnoses.