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Frequently Asked Questions


Will you be handling my Connecticut case or some other lawyer in your office?

We hear stories all the time from clients who meet with the managing partner of a law firm when the lawyer is hired, only to find out that the client’s matter is quickly handed off to a brand new lawyer to handle. This happens because the managing partner’s time is deemed too valuable to spend working on the client’s matter. You won’t find that with us. We work collaboratively on files in our office, which means that one lawyer is in charge of your file from beginning to end, which means that the lawyer will establish strategy, keep track of court dates, communicate with opposing counsel and stay in touch with you. It also means that through the use of our collaborative approach, you may have different lawyers handling different aspects of your matter at different times. Don’t worry — the supervising lawyer will be the lawyer who is ultimately in charge of your file at any given time. Call us to chat about your case — 203-822-7006.

What should I wear when I go to court?

Generally speaking, when you go to court, you should dress nicely, but a suit is not necessary. Men should wear clean slacks and a button down shirt — no tie is necessary. No overly fancy or expensive jewelry, and be cleanly shaven. Women should also dress nicely and in subdued tones, no bright colors, expensive or excessive jewelry. Make sure your mobile phone is turned off at all times when in court. Do not bring in any backpacks or large bags with personal possessions, as all bags will be sorted through upon entrance to the court. No sharp objects, cameras (excluding cellphones), lighters, food, drink or similar items allowed in the court.

How much time do I have to bring a lawsuit in Norwalk, Connecticut?

The “statute of limitations” is the deadline that a person has to file a lawsuit. In Connecticut, there are specific statutes of limitation for each specific type of claim that can be filed, whether it is the breach of a written contract (6 years), breach of an oral contract (3 years) or a claim for personal injuries (2 years). But wait . . . there are specific rules for certain types of claims within the personal injury category, such as claims involving a municipality (such as a slip and fall on a city sidewalk resulting in injuries) which requires a specific, detailed, written notice to the town or city clerk within six months of the date of injury, or involving the state of Connecticut (car crash involving a State of Connecticut Department of Transportation truck, for example) which requires specific written notice to the Connecticut Claims Commissioner required no later than one year after the date of injury.

This is a potentially complicated area of law, with some cases having more than one applicable statute of limitation, and there are many instances where people are denied the ability to bring a lawsuit for failure to file a timely claim. We are careful in calculating the statute of limitations in each case, so don’t rely upon the outline described above. The best course of action is . . . don’t wait to file a claim for injuries sustained or you might be out of luck: Immediately contact an attorney to ensure your rights are protected. If you think you have a claim, call us immediately to determine the statute of limitations in your case. 203-822-7006.

How can you assist me in preparing my case?

Social media posting — don’t post anything on social media about anything to do with your case.

Discussing case — don’t discuss your case with anyone other than your lawyer. Especially don’t discuss your case with any insurance adjusters; they are there to minimize or eliminate any basis that you might have for filing a claim.

Documenting your injuries — keep track of the names of each and every doctor, medical provider, radiologist, nurse, etc. that you have seen in connection with your case.

Work with us by reading our email instructions, meeting with us when needed and becoming fully informed about your injuries and impact of those injuries on your life.

Am I entitled to look at my file?

We welcome clients in our office anytime to review their file with or without an attorney. Just call us anytime and set up an appointment.

Personal Injury:

How much will hiring you cost me?

Personal injury actions are handled according to the Connecticut General Statutes which sets for a contingency fee schedule that establishes attorney fees in Connecticut. If nothing is collected, then there is no fee. If there is a recovery made, whether by way of settlement, jury verdict, court or arbitrator’s decision, then the law firm is paid the contingency fee that applies to the amount of the recovery. Questions? For information about fee percentages and structure, call us to speak with one of our lawyers about your case at 203-822-7006. We’d be happy to speak with you.

How long will my case take to finish?

The length of a personal injury litigation varies depending upon many factors, including the severity or complexity of the injuries, when the lawsuit is filed, the schedule of the court, and many other factors. Connecticut’s current jury trial calendar runs approximately one and a half years from the date that the suit is commenced. Although cases may vary, we try to have your case ready for suit within six months of the date you hire us. Short answer: About 18 months if you go the full distance, shorter if there is a settlement.

Questions? Please sign up for our regular newsletter, which covers many of the issues and questions asked here. You can sign up at, by filling in your email and/or mailing address. It’s FREE. And if you would like to speak with one of our lawyers about your case, just call us at 203-822-7006. We’d be happy to speak with you.

Will I have to testify? Will I have to go to court?

Most likely you will have to testify in support of your claims. This typically means that the insurance company’s lawyer will take your deposition — a recorded and transcribed statement under oath. Don’t be fooled — even though it usually takes place in a lawyer’s office, it is courtroom testimony and may have a huge impact on the outcome of your case. More than 90 percent of personal injury cases in the Stamford, Bridgeport and New Haven courts settle before trial. Despite that fact, our approach to each litigation focuses on educating clients about their injuries, preparing clients for the litigation process, how to prepare to go to court, and how to prepare for a deposition. Therefore, even though the statistical chances that you will have a jury trial are small, we prepare you for a jury trial because that is what drives higher compensation for clients. Don’t worry — we’ll make sure you are comfortable and prepared for all court events!

Questions? Please sign up for our regular newsletter, which covers many of the issues and questions asked here. You can sign up at, by filling in your email and/or mailing address. It’s FREE. And if you would like to speak with one of our lawyers about your case, just call us at 203-822-7006. We’d be happy to speak with you.

What is a deposition and will I need to give one?

A deposition is a recorded statement under oath that usually takes place in our office or the other attorney’s office. This is a question and answer (the opposing lawyer is asking the questions, and you are answering those questions!) session, which is recorded by a court reporter. Your answers in the deposition are courtroom testimony and fully admissible in court. Therefore, your deposition may be the most important part of preparation of your case for court.

At Harris, Harris and Schmid, we have devoted a large amount of time to creating a process designed not only to inform you how to best handle deposition questions, but also how to be relaxed and comfortable during this process. The deposition is not only about how to answer the questions that are asked, but also ensuring that you present well during the deposition — we want the opposing lawyer to have a favorable opinion of your ability to testify well under pressure. Are you knowledgeable about the event, your injuries and how they have impacted your life? Are you a confident and convincing witness? We work with you to make sure you hit all the important points in your deposition.

We’d be happy to speak with you about deposition preparation, what a deposition involves and the key things NOT to do in a deposition. 203-822-7006.

Why do you videotape your depositions?

Harris, Harris & Schmid videotapes most of the depositions that we take of the other parties to a case. These include depositions of the defendant in the case, the defendant’s expert and any fact witnesses that may be necessary to depose before your case goes to trial. We have invested in equipment that makes taking video depositions possible for every single deposition and this gives us several advantages in litigating cases. Our video capabilities also have proved invaluable in other contexts, such as execution of estate planning documents that may be contested, accident scene depictions and more. You know what they say — a picture is worth a thousand words!

What do I need to know for my deposition and do I need to prepare?

We prepare you for your deposition by reviewing all pertinent facts about your case, reviewing the themes of your case with you, and doing live question and answer sessions with you, the client. We’ve been doing this a while so we already know many of the questions that you will be asked. And as a client, you will be the beneficiary of that information! No need to worry about specific dates of treatment, names of people and places and specifics. By the time your deposition comes around, maybe a year post-incident — it would be unlikely you would remember specific details like that. Who can remember what you had for breakfast last week on Tuesday? Our newsletter contains information about personal injury cases, trial practice and other matters. Sign up at

What are common mistakes in a deposition?

The most common mistake in depositions is testifying about something that you are not sure about. Lying is the kiss of death in a deposition. Guessing about the correct answer is next to lying because the other lawyer will say you weren’t guessing . . . You were lying. Our preparation of clients is focused on making sure you know how to answer any questions that you are not sure about. The reason for this is that, more important than anything else in your case is your credibility. Credibility is the sense that a jury or judge gets that you are telling the truth. So, if your credibility is in doubt because you guessed about the name of a doctor, or the date of a car crash, why should a judge or jury believe you when you discuss how injured you are? For many questions, testifying that you “don’t recall” or “I can’t remember” are perfectly fine answers in a deposition. As part of our preparation of your case, you will understand the difference and know how to answer questions that you can’t remember the answers to.

Do I need to pay taxes on my personal injury settlement?

The short answer is “no,” you don’t need to pay taxes on a personal injury recovery. If you invest the proceeds of your recovery, however, you will need to pay taxes on any income on that investment. We aren’t accountants! You should consult a tax specialist to determine your specific tax liability for any personal injury recovery you may have.

What are common defenses to personal injury lawsuits?

Pre-existing injury — The insurance defense industry will try to blame your current injuries on anything that happened to you in your lifetime. In a car accident twenty years ago? The insurance company will try to link your current pain and suffering to that incident. Don’t worry, we know how this issue can actually work to your benefit.

Comparative negligence — “You caused some, or all, of your current injuries.” The insurance industry will argue that you were looking the wrong way, or that you were traveling too fast, or that you . . . Whatever the insurance company can think up!

Failure to mitigate damages — You are required to do everything in your power to get yourself better, and limit your losses. This includes looking for suitable employment (within your limitations), making sure you don’t miss doctor’s appointments and following your doctor’s advice.

Why is the Probate Court involved in my personal injury case?

You may be wondering why the Connecticut probate court may become involved in a personal injury litigation? Connecticut’s probate courts may become involved in a personal injury case when a minor child, incapacitated or deceased person is involved. The probate court has jurisdiction over personal injury matters when any of these types of considerations are involved. Harris, Harris & Schmid is routinely involved in probate court matters; we handle probate administration, conservatorship proceedings and juvenile proceedings as a matter of course, so you are in good hands if your personal injury matter falls into one of these categories.

Questions? Please sign up for our regular newsletter, which covers many of the issues and questions asked here. You can sign up at, by filling in your email and/or mailing address. It’s FREE. And if you would like to speak with one of our lawyers about your case, just call us at 203-822-7006. We’d be happy to speak with you.

How much is my case worth?

You case is worth more or less depending on how serious your injuries are, whether your injuries are temporary or permanent, whether or not your injuries impact your ability to make a living, and the pain and suffering that you may experience as a result of the injuries. Your lost wages, possible lost future wages, pain and suffering and loss of enjoyment of life’s activities are all part of the equation. Of course, all of this is assuming that you have a good liability case. As you can see, these aren’t mathematical calculations so much as they are qualitative determinations. But based on the above basic categories, and other factors, we can determine what the extent of the losses are, determine how seriously they will impact your life’s activities, and your ability to carry on with your normal life’s activities.

Questions? Please sign up for our regular newsletter, which covers many of the issues and questions asked here. You can sign up at, by filling in your email and/or mailing address. It’s FREE. And if you would like to speak with one of our lawyers about your case, just call us at 203-822-7006. We’d be happy to speak with you.

What are “liens” and how do they impact my case?

When you hire Harris, Harris & Schmid to represent you in a personal injury case, one of the first things we will do is speak with you about whether you may have received Medicare, Medicaid or any other governmental benefits that may impact the outcome of your case. If so, you may have to pay some or all or none of this amount from the proceeds recovered in your case. This amount is subject to review and revision, and we routinely do this with every case to ensure that you don’t pay more than you are legally obligated to pay. Why pay more than you actually owe? Lien’s may include, for example, Connecticut state or municipal aid, hospital expenses, incarceration liens, any child support liens, workers’ compensation payments toward your wages or medical bills, and similar such benefits. We address liens up front and immediately upon hiring so that we can have a good understanding of what funds must come out of the proceeds of any case resolution.

When my case resolves, is it documented in writing?

All settlement documents are presented to clients well in advance of any final settlement of a personal injury case. We want to make sure that you have all documents, copies of checks, reviews of the file, before you decide to settle your case. After all, you have the final say on any settlement of your case.

Why do I get so many emails from you once my case gets underway?

Education of our clients regarding the civil litigation process, the injuries that are likely to result from certain types of accidents, how long the process in court will last, and what to expect. We feel that it is better that you get this information as your case progresses, and at a time when it makes sense to you, so that you will be comfortable with what is taking place, and where you are in the process. As a famous furniture commercial once said: “An educated consumer is our best customer!” That applies much more when we are talking about your health and well-being than it does with a furniture purchase! You need serious legal counsel, and you get it with Harris, Harris & Schmid. We are invested in your success.

Questions? Please sign up for our regular newsletter, which covers many of the issues and questions asked here. You can sign up at, by filling in your email and/or mailing address. It’s FREE. And if you would like to speak with one of our lawyers about your case, just call us at 203-822-7006. We’d be happy to speak with you.

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