Plaintiff’s Deposition Outline

Deposition of the Plaintiff

  1. name (maiden name)
  2. married ever married before
  3. children
  4. where born
  5. where grew up
  6. graduate from high school
  7. any further education
  8. any other training or degrees.
  9. any relatives in the county
  10. any military service criminal arrests?
  11. convictions?


what are your symptoms from the wreck prior to the wreck ever have any problem with list areas.

  1. up until you were 21 describe any injuries or illnesses that caused you to see a physician or chiropractor
  2. from 21 until the time of the accident
  3. condition one week before the wreck.
  4. ever been to a chiropractor before the wreck
  5. ever had a massage before the wreck
  6. ever gone to a hospital before the wreck.
  7. were you taking any prescription medication before the wreck
  8. before the accident did you ever have any of the symptoms you complained of after the wreck what were those symptoms
  9. 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.
  10. Ever filed a worker”s compensation claim?
  11. Ever suffer any type of injury or illness that caused you to go to a hospital Think hard.
  12. Ever been involved in litigation before
  13. Ever made a claim for compensation stemming from a incident
  14. Ever hired a lawyer before
  15. who is your family doctor
  16. who is your obgyn
  17. what other doctors have you ever seen prior to the wreck, what health care insurance did you have afterwards?

the accident

  1. do you were glasses or have hearing problems
  2. where did the accident occur
  3. Where were you going
  4. Who was in your car
  5. Who was in the other car
  6. Are there any witnesses you are aware of and what do they know
  7. What kind of car were you driving
  8. What kind was the defendant driving
  9. Tell me how the accident happened
  10. How fast were you going
  11. How fast was defendant going
  12. Characterize the impact as light, medium, or severe
  13. What damage was apparent on your car
  14. On the defendants car.
  15. Show the accident photos body strike any part of the car?
  16. What happened to your body when the cars collided?
  17. How long before the police arrived
  18. Did you say anything to the defendant
  19. They say anything to you
  20. Anyone at the scene say anything
  21. What did you say to the officer
  22. Was there a paramedic there.
  23. Talk to them
  24. Remember if anyone was cited.
  25. Were you hurt at the scene
  26. Where did it hurt
  27. Cars towed or driven away?
  28. After
  29. What did you do that night
  30. The next day

Medical treatment history

  1. What was the first treatment you sought
  2. What were your complaints
  3. Next
  4. When did you start to feel better.
  5. What got better first
  6. 1 month
  7. 3 months
  8. 6 months
  9. after one year after how did you feel still have any problems today
  10. what do your doctors tell you about your prognosis
  11. how did you find your lawyer
  12. how referred to each doctor
  13. paid your medical bills yet?
  14. Travel since the accident
  15. Filed bankruptcy
  16. loss of consortium questions


  1. Current job
  2. Then
  3. Wage
  4. What time did you miss