Plaintiff’s Deposition Outline
Deposition of the Plaintiff
- name (maiden name)
- married ever married before
- children
- where born
- where grew up
- graduate from high school
- any further education
- any other training or degrees.
- any relatives in the county
- any military service criminal arrests?
- convictions?
pre-existing
what are your symptoms from the wreck prior to the wreck ever have any problem with list areas.
- up until you were 21 describe any injuries or illnesses that caused you to see a physician or chiropractor
- from 21 until the time of the accident
- condition one week before the wreck.
- ever been to a chiropractor before the wreck
- ever had a massage before the wreck
- ever gone to a hospital before the wreck.
- were you taking any prescription medication before the wreck
- before the accident did you ever have any of the symptoms you complained of after the wreck what were those symptoms
- before the wreck did you ever suffer any kind of injury that led to symptoms similar to the ones you claim to suffer as a result of the wreck any prior accidents of any type any prior car accidents.
- Ever filed a worker”s compensation claim?
- Ever suffer any type of injury or illness that caused you to go to a hospital Think hard.
- Ever been involved in litigation before
- Ever made a claim for compensation stemming from a incident
- Ever hired a lawyer before
- who is your family doctor
- who is your obgyn
- what other doctors have you ever seen prior to the wreck, what health care insurance did you have afterwards?
the accident
- do you were glasses or have hearing problems
- where did the accident occur
- Where were you going
- Who was in your car
- Who was in the other car
- Are there any witnesses you are aware of and what do they know
- What kind of car were you driving
- What kind was the defendant driving
- Tell me how the accident happened
- How fast were you going
- How fast was defendant going
- Characterize the impact as light, medium, or severe
- What damage was apparent on your car
- On the defendants car.
- Show the accident photos body strike any part of the car?
- What happened to your body when the cars collided?
- How long before the police arrived
- Did you say anything to the defendant
- They say anything to you
- Anyone at the scene say anything
- What did you say to the officer
- Was there a paramedic there.
- Talk to them
- Remember if anyone was cited.
- Were you hurt at the scene
- Where did it hurt
- Cars towed or driven away?
- After
- What did you do that night
- The next day
Medical treatment history
- What was the first treatment you sought
- What were your complaints
- Next
- When did you start to feel better.
- What got better first
- 1 month
- 3 months
- 6 months
- after one year after how did you feel still have any problems today
- what do your doctors tell you about your prognosis
- how did you find your lawyer
- how referred to each doctor
- paid your medical bills yet?
- Travel since the accident
- Filed bankruptcy
- loss of consortium questions
LOST WAGES
- Current job
- Then
- Wage
- What time did you miss