Choosing the Right Lawyer is No ACCIDENT- A Personal Injury Guide - By Jeff Adelman (2025 Edition)

Choosing the Right Lawyer is No Accident
has surveillance of you doing something you say you “never” do? Stay
away from unnecessary, absolute words.
5. Counting Mississippis. I alternatively call this the “Thoughtful Pause
Rule.” For those of you that have played touch football, you know you
can’t rush the quarterback until you have counted Mississippi 3-7 times,
depending on who makes the rules. It is essential that you take a
thoughtful pause or count “Mississippis” to collect your thoughts before
you speak and before any words come out of your mouth. This gives
you a chance to think and additionally gives your attorney time to object
if necessary. DO NOT cut off the defense attorney while they are
questioning you. You may take the question in a different direction than
the defense attorney intended and disclose something that the defense
attorney would never have known but for you not following this rule. Let
the attorney finish the question, count your “Mississippis,” and only then
answer. You should handle every single question this way. There is no
rush. Take your time and give yourself a thoughtful pause before
answering questions.
6. “OBJECTION!” means keep quiet. Your attorney is either making a
legal objection and alerting you to pay close attention before answering.
If you are following the “Mississippi rule,” you shouldn’t have a problem
with this. However, you still may have to answer these questions. But
the next rule talks about when you should not answer a question that is
objected to by your attorney.
7. Attorney-client privilege. What you and your attorney talk about is off
limits to the opposing attorney! This can include if your attorney referred
you to any medical provider. Do not divulge ANYTHING your lawyer
tells you. If your attorney uses this objection and tells you not to answer,
you should not. This is another reason you must take a thoughtful pause
before answering questions. You want to make sure the other attorney is
not asking a question that they are not entitled to an answer to.
8. Review documents. You should review your answers to
interrogatories AND these rules at least twice prior to your deposition.
As I mentioned earlier, you may bring your answers to interrogatories
with you to your deposition if you need to refresh your memory. Also, if
you are taking a lot of prescription medications, or are worried that you
Jeff Adelman, B.C.S., Esq. 35