This Personal Injury Deposition Commonly Asked Questions document sets forth many
of the essential questions that must be directed at the plaintiff 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 plaintiff in a personal
injury case and customize it accordingly to fit the situation. This document should be
used by defendants or their attorneys when conducting depositions in a personal injury
1. Preliminary Questions and General Background
A. State and spell your first name for the record.
B. Did you review any documents before coming here? If so, which documents?
C. 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?
D. Have you ever gone by any other name?
E. Do you have more than one last name?
F. Where do you currently live?
G. What is your phone number?
H. What is your birth date?
I. Where were you born?
J. What is your Social Security Number?
K. What is your drivers license number?
L. Are you currently married? If you are married, what is the full name of your spouse
and any former spouses?
M. What were your previous addresses?
N. Have you been involved with any other lawsuits in which you were a party within the
last 6 years?
2. Educational History
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?
3. Medical History Pre-Occurrence
A. Did you have any conditions before occurrence?
B. What are the names and addresses of the doctors you consulted before the
C. Did you have any medical conditions in the 5 years before the occurrence?
D. What prescriptions have you taken within 1 year of occurrence to present?What is
your doctor’s name? What is the date of your last physical?
E. Have you ever been hospitalized? Which hospitals have you visited? What was the
reason for each visit? What treatment did you receive?
F. Have you had any surgeries?
G. Have you been involved with any other similar occurrences between _____________
[Instructions: Insert date] to present? What was the medical treatment you received
for each similar occurrence?
H. Have you ever injured your _____________ [Instructions: Identify injured area]
I. Did any of your injuries from prior occurrences involve the same body part that is the
subject of your complaint?
J. Did you ever play sports?
K. Do you have a regular doctor you visit?
L. Do you have health insurance?
M. Do you suffer from any major illnesses? Do you suffer from diabetes, heart disease,
4. Employment History
A. Are you currently employed? If so, who is you employer? H
i. How long have you been employed?
ii. What is your position?
iii. What is your monthly income?
iv. What are your duties at this job?
v. What is your job title?
vi. How many hours a week do you work?
vii. What is your rate of pay?
viii. What physical activities are involved with your work?
ix. What is the name of your supervisor?
B. Have you ever been unemployed? If so, how long? For what reason were you
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C. If not currently employed, where were you last employed before sustaining your
i. What was your position?
ii. What was your monthly income?
iii. What were your duties at this job?
iv. What was your job title?
v. How many hours a week do you work?
vi. What was your rate of pay?
vii. What physical activities were involved with your work?
viii. What was the name of your supervisor?
5. Activities Prior to Alleged Injury
A. Did you regularly exercise before receiving your alleged injuries? What was the
frequency of such activity?
B. Do you or did you belong to any health clubs or groups?
C. Did you have any household chores?
D. Were you in any way active within your community?
6. 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,
A. Can you describe the scene of the occurrence?
B. What time was the occurrence?
C. Who were you with?
D. How did you conduct yourself prior to the occurrence?
E. Who was the first to arrive after the incident?
F. How did you conduct yourself after the occurrence?
G. Who witnessed the occurrence?
H. Did police officers, paramedics or any other third party arrive to assist? Was a police
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I. 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?
J. Who did you speak to immediately after the injury?
K. Did you report the occurrence?
7. Medical Care and Treatment
A. Did you feel pain immediately?
B. Where did you feel pain?
C. What happened immediately after the injury?
D. Were you able to get up on your feet?
E. Did you go to the doctor the same day of the injury? If so, what was the name of the
doctor or facility you visited? What treatment did you receive?
F. What body parts hurt immediately after the injury?
G. Which doctors did you see subsequent to the occurrence? What kind of treatment did
you receive? Were you given medication? What body parts did he/she treat?
H. How long did you receive any physical therapy? Did the treatment help?
I. Did you receive the injections? Who gave you the injections? Did the injections help?
J. Are you experiencing any pain right now? If yes, what