Personal Injury Deposition Commonly Asked Questions - Defendant

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									This Personal Injury Deposition Commonly Asked Questions document sets forth many
of the essential questions that must be directed to the defendant in a personal injury
case. This list provides an attorney with a solid foundation from which to conduct the
deposition. Furthermore, this document ensures that crucial questions are not
overlooked. An attorney should review this list before deposing a defendant in a
personal injury case and customize it accordingly to fit the situation. This document
should be used by plaintiffs or their attorneys when conducting depositions in a personal
injury case.
               Personal Injury Defendant Deposition Commonly Asked Questions


1. State and spell your first name for the record.
2. Did you review any documents before coming here? If so, which documents?
3. Did you meet with your attorney before coming here? If so, how long? How many meetings
   did you have? When did you meet with attorney?
4. Have you ever gone by any other name?
5. Do you have more than one last name?
6. Where do you currently live?
7. What is your phone number?
8. What is your birth date?
9. Where were you born?
10. What is your Social Security Number?
11. What is your driver’s license number?
12. Are you currently married? If you are married, what is the full name of your spouse and any
    former spouses?
13. What were your previous addresses?
14. Have you been involved with any other lawsuits in which you were a party within the last 6
    years?
15. What formal education have you received?
       A. What is the highest level of education you completed?
       B. What are the names of all schools you attended since high school?
       C. What is the highest educational degree you obtained?
16. What is your experience with _____________ [Instruction: Insert description of activity
    that caused injury]. At which age to you begin this activity?
17. Do you have a license to engage in this activity?
       A. Has this license been suspended or revoked at anytime?
       B. Are there any restrictions on this license?
18. Do you have any physical impairments?
19. Can you describe the scene where the injury took place?
        A. Were you indoors or outdoors?
        B. What was the weather?
        C. How was the lighting?
        D. [Comment: User should ask specific questions related to the relevant scene. User
           will want to get a detailed description of the scene]
20. Have any conditions at the scene of the injury changed since the time of the injury? Have
    additional precautions been taken?
21. Can you take us through events that led to the injury?
        A. What was your conduct before the injury occurred?
        B. What was plaintiff doing?
22. How did the injury occur?
23. When did you first notice that plaintiff had been injured?
        A. How close were you to the plaintiff?
        B. Where were you when the plaintiff was injured?
24. Can you describe the scene of the occurrence? [Comment: User should illicit all relevant
    testimony pertaining to the specific situation. If the injury was an auto accident, then
    User should ask the deponent to describe the roads, the signage, road conditions,
    weather, visibility, distractions, vehicles, etc.]
        A. What time was the occurrence?
        B. Who were you with?
        C. How did you conduct yourself prior to the occurrence?
        D. Who was the first to arrive after the incident?
        E. How did you conduct yourself after the occurrence?
        F. Who witnessed the occurrence?
        G. Did police officers, paramedics or any other third party arrive to assist? Was a police
           report created?
        H. Did you have any conversations with the defendant, or any other party regarding the
           occurrence? What statements did you make? What statements were made to you?
25. Who did you speak to immediately after the injury?


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26. Did you report the occurrence?
27. Who witnessed the injury?
        A. What is their contact information?
        B. Was any other party involved?
28. Have any criminal charges been filed against you in relation to this injury?
29. What conversation did you have with plaintiff before the injury?
        A. What was said?
        B. Who was present?
        C. Where were you?
30. What conversations did you with plaintiff after the injury?
        A. What was said?
        B. Who was present?
        C. Where were you?
31. Have you made any statements to any parties besides the plaintiff related to the injury?
    Whom have you spoken to?




© Copyright 2012 Docstoc Inc.                                                                  4

								
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