The deposition transcripts are a treasure trove for facts that can establish your prima facie case.  You might want to read certain testimony that can address contested issues in the defendant’s Answer.  For example, the time, date, location of an accident, as well as the issue of “contact” between the offending vehicle and your client’s vehicle – these items can confirm these issues.

Whenever the defendant has not been clear on a topic, it is always safe to read the testimony of the defendant to “make a record.”