A deposition is a type of discovery in which the lawyer for a party takes your testimony while you are under oath, just like you would be in court.  In Oregon, the adverse party is allowed to ask you common deposition questions about any matter that is “not privileged, which is relevant to the claim or defense of the party seeking discovery or to the claim or defense of any other party.”  Oregon Rules of Civil Procedure (ORCP 36 B1).  This allows the other side a lot of leeway to ask you questions relating to your case.

At the deposition a court reporter will record all questions and answers and will later make a written copy to distribute to both sides.

If your case goes to trial and if your testimony at trial differs from your testimony during the deposition, the other lawyer will use your deposition to impeach you.  A common deposition dialogue is to ask you – in front of the jury – whether your under-oath testimony at the deposition was untruthful, or whether you are not telling the truth at trial.

Common Deposition Questions

Common Deposition Questions

Depending on the claims you made in your personal injury case, deposition questions can typically be grouped into 4 to 5 categories:

  1. Background information.  This includes detailed questions about places you have lived, your work history, your education, prior injury claims, your criminal history, etc.
  2. Your physical condition before your injury compared to after.  This includes the various activities you used to participate in compared to present activities, doctors you have treated with, prior hospital stays, prior emergency room visits, and your current status.
  3. In-depth details about how you were injured.  In an auto accident case you will be asked very specific questions leading up to how the accident happened, the speed of the involved vehicles, what you saw, whether there were witnesses and any statements they made, statements made by you at the accident scene, the forces of impact, and damage to the vehicles.
  4. Specific details about your injuries, including when you first realized you were injured, where you suffered pain, the extent of your pain, and the treatment you received.
  5. If you make a claim for loss of future earning capacity, you will be subjected to many questions about your employment history, including providing tax returns and having to answer detailed questions about your employment.An experienced attorney will thoroughly prepare you for your deposition.
Ryan Hilts is a personal injury lawyer in Lake Oswego and Portland area.  For more information on common deposition questions, contact Ryan today.

Ryan is a member of the Oregon State Bar, the Washington State Bar, and the Oregon Trial Lawyers Association.

Ryan was selected to the list of top young attorneys in Oregon by the American Registry, Oregon’s Outstanding Young Lawyers, Portland Monthly Magazine, and “Rising Star” by Super Lawyers Magazine in 2011, 2012, 2013, 2014, 2015 and 2016.

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I was involved in a personal accident case where the insurance company denied responsibility for nearly two years and we eventually had to go to trial. Ryan helped me through the whole process, answering my questions and keeping me informed as to what was next in the process. My first recommendation is to never get involved in an accident but if you are and an insurance company is trying to treat you unfairly, contact Ryan and he will make sure you’re informed about your rights and your best course of action.  Can’t imagine where I’d be in this process without his expertise. Thanks again Ryan.


I was recommended to Mr. Hilts by a friend when I had my car accident. I was very impressed with his knowledge and the way he guided me through the process. I appreciated that he always returned my calls and kept me informed about the progress of my case.


I could never say enough good things about Ryan. He was always there to take my calls and answer all of my questions. I really felt like he was working for me; like I was his top priority.


Ryan is a terrific lawyer and a better person. He went above and beyond to reach a settlement in my case and believed in it when no one else did. He’s very intelligent and caring and is always putting the best interests of his clients before his own. Ryan knew more about my case than I even did. He is truly dedicated to his clients, and I can not explain how much I honestly appreciated that. I recommend that you give him a shot if you need to hire an attorney. He won’t let you down.


It was our good fortune to have Ryan Hilts as our attorney. Ryan helped our children avoid a lawsuit and get a successful settlement. He taught us so much. He represented our family with integrity.