Direct-Examination of Donna
(Personal Injury Accident Victim)
BACKGROUND
- FULL NAME AND ADDRESS
- HOW LONG HAVE YOU LIVED THERE?
- WHO DO YOU LIVE THERE WITH?
- WHAT ARE YOUR CHILDREN’S NAMES AND AGES?
- HOW LONG HAVE YOU BEEN MARRIED?
- HOW LONG HAVE YOU KNOWN RON?
BEFORE THE ACCIDENT
- BEFORE THE ACCIDENT, WHAT WAS GOING ON IN YOUR LIVES?
- WHY DID RON CHOOSE TO LIVE IN THE TRAILER?
- WHEN WAS YOUR HOUSE EXPECTED TO BE DELIVERED?
- WHAT WAS YOUR FAMILIES FINANCIAL PLAN?
- WHAT TYPES OF ACTIVITIES DID THE TWO OF YOU ENJOY BEFORE THIS ACCIDENT?
- HOW WAS RON’S HEALTH BEFORE THE ACCIDENT?
- HOW MUCH DID RON ENJOY HIS JOB BEFORE THE ACCIDENT?
- HOW MUCH DID IT MEAN TO RON TO BE A GOOD WORKER AND A MECHANIC?
DAY OF THE ACCIDENT
- JUST BEFORE THE ACCIDENT WHERE WERE YOU?
- HOW DID YOU FIND OUT ABOUT THE ACCIDENT?
- DESCRIBE WHAT YOU SAW WHEN YOU SAW RON
- DESCRIBE RON’S MOOD
- WHAT HAPPENED IN THE ER?
- HOW WAS RON DISCHARGED FROM THE ER?
- WAS HE ABLE TO LIVE IN THE TRAILER?
- WHERE DID THE TWO OF YOU STAY AT YOUR FATHERS HOUSE?
- WHAT DID THE DRS SAY ABOUT RON’S CONDITION IN THE ER?
- HOW WAS RON FEELING THE DAYS FOLLOWING THE ACCIDENT?
- WAS HE ABLE TO SHOWER BY HIMSELF?
- WAS HE ABLE TO GO TO THE BATHROOM BY HIMSELF?
- HOW DID HE GET AROUND EARLY ON?
- WAS THE PAIN MEDICATION HELPING AT ALL ?
- HOW WAS HE SLEEPING?
APRIL
- DID YOU SEE RON’S KNEE IN APRIL BEFORE THE SURGERY?
- WHERE YOU THERE WHEN THEY SUCKED THE GOOP OUT?
- WHAT DID YOU SEE?
- HOW DOES RON FEEL ABOUT NEEDLES?
- HOW WAS HE DOING AFTER THE FIRST SURGERY?
- DURING APRIL AND MAY HOW WAS HE GETTING AROUND?
- HOW WAS HE GOING TO THE BATHROOM OR SHOWERING?
- HOW WAS HE GETTING BACK AND FORTH TO PT?
- AT THIS TIME YOUR HOUSE IS DONE, HOW WAS IT MOVING IN WITH RON’S INABILITY TO HELP?
- HOW WERE YOU MAKING ENDS MEET DURING THIS TIME PERIOD?
- HOW WAS RON FEELING ABOUT BEING OUT OF WORK?
- HOW DID HE FEEL ABOUT HIS RECOVERY?
JUNE SURGERY
- WHAT TYPE OF SURGERY WAS DONE IN JUNE?
- HOW WAS HE DOING AFTER THAT SURGERY?
- DURING THE PT FROM JUNE TO OCTOBER WAS HE GETTING BETTER AT A RATE HE WAS HAPPY WITH ?
- WHY DID HE SWITCH DRS?
- AFTER TALKING TO HIS NEW DRS HOW WAS RON FEELING ABOUT HIS CAREER?
- WHAT DID HE DO TO TRY AND SEEK OUT OPTIONS FOR ANOTHER CAREER?
OCTOBER
- WHEN RON WENT BACK TO WORK IN OCTOBER HOW WAS HE DOING?
- HOW DID HE FEEL ABOUT GETTING THE EASIER JOBS?
CURRENTLY
- HOW HAS RON’S INJURY AFFECTED HIS JOB ?
- HOW HAS RON’S INJURY AFFECTED HIS MOBILITY?
- HOW HAS RON’S INJURY AFFECTED HIS MOOD?
- HOW HAS RON’S INJURY AFFECTED HIS RELATIONSHIP WITH YOU
- WITH HIS CHILDREN?
Back to Sample Trial Materials
Back to Attorney
Help Center

