A: An examination for discovery is when your lawyer asks the person who caused the accident questions under oath, and ICBC's lawyer asks you questions. It takes place in a boardroom at a court reporter's office or law office-not in a courtroom. The only people present are the lawyers, the parties to the lawsuit and the court reporter. By agreement, a spouse who was not injured may attend for moral support.

If the law does not require you to answer a certain question your lawyer will object to the question and instruct you to not answer it. He will object to questions on subjects that are:

• your state of health, your activities and your employment before the accident,
• the accident itself, and
• how you have progressed over time since the accident in terms of your pain, psychological state, limitations, activities, household chores and work,
• the steps you have taken to get better and the efforts you made,
• your present condition.

Your lawyer will meet with you to help you prepare for the examination. If your sworn testimony contradicts the clinical notes and reports of your doctors and other treatment practitioners or your statements to the police and to ICBC after the accident, your credibility will be reduced; therefore, it is well worth your time to review these documents before your discovery.

Most ICBC lawyers are not rude or obnoxious at your discovery. In fact, many have learned from experience that they obtain many more favourable admissions from injured claimants by being very nice to them. The ICBC lawyer will ask you about:

• your state of health, your activities and your employment before the accident,
• the accident itself, and
• how you have progressed over time since the accident.

ICBC's lawyer may also ask you what 'percent' you improved at various times since the accident. If you cannot answer such a question on a percentage basis, you do not have to do so; you may simply describe how you felt and what you have been able to do during various periods since the accident.