Plaintiff's Deposition Outline
- name (maiden name)
- married ever married before
- 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?
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 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 dayMedical treatment history
What was the first treatment you sought
What were your complaints
When did you start to feel better.
What got better first
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
loss of consortium questionsLOST WAGES
What time miss