does deposition ofte happen right before msc hearing?
Yes, the deposition would take before the Mandatory Settlement Conference, because discovery closes after the MSC. That means that if either party obtains additional information after the MSC, they will not be able to use that information in trial. Further, depositions often give defense attorneys leads as to where they may find additional information. Thus, they would need time to obtain that information after the deposition, but before the MSC.
I can see why Ms. Wallace says you don't want a deposition because often times people can give testimony that is damaging to their case. On the other hand, assuming everything is on the up-and-up with your case, it can only benefit you to have certain information on the record. For example, if you testify that you have pain in your left shoulder in a deposition today. When a doctor evaluates you years down the road, she can see that you were complaining of pain to your left shoulder during your deposition to confirm the consistency of your complaints.