If you are required to give a recorded statement to the insurance company or have your deposition taken in your auto accident case, follow these rules as you answer the questions.  They can be summarized as follows:  listen carefully to the question, pause and think before you answer, and give as short an answer as possible.
  1. Listen carefully to the question.
  2. Be sure you hear and understand the question before answering.
  3. Pause and think before you answer.
  4. Answer only the question asked.
  5. Answer in a deliberate and thoughtful manner.
  6. Give short answers.  Answer “Yes” or “No” when possible.
  7. Do not guess.  Answer only what you know and remember.
  8. If you can’t remember, state that you don’t recall.
  9. If you don’t know, state that you don’t know.
  10. Do not exaggerate.
  11. Answer boldly when your answer is favorable to your case.
  12. Stick to truthful answers.
  13. Speak clearly and with a sincere and pleasant voice.  Don’t get emotional.
  14. Look at any drawings or documents carefully before answering.

Remember:  the recorded statement is for the benefit of the insurance company.   You can’t win your case in a statement, you can only lose.  So be truthful, but don’t volunteer information. 

Bonus tip:  Don't give a statement without first discussing your case with your lawyer and having your lawyer present when you give your recorded statement to the insurance adjuster.