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?



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

  11. up until you were 21 describe any injuries or illnesses that caused you to see a physician or chiropractor
  12. from 21 until the time of the accident
  13. condition one week before the wreck.
  14. ever been to a chiropractor before the wreck
  15. ever had a massage before the wreck
  16. ever gone to a hospital before the wreck.
  17. were you taking any prescription medication before the wreck
  18. before the accident did you ever have any of the symptoms you complained of after the wreck what were those symptoms
  19. 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 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 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?


What did you do that night

The next day

Medical treatment history

What was the first treatment you sought

What were your complaints


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 find your lawyer

how referred to each doctor

paid your medical bills yet?

Travel since the accident

Filed bankruptcy

loss of consortium questions


Current job



What time miss

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