Cross-Examination of Diana Simpson
(Defendant Driver)

BACKGROUND

  • FULL NAME AND CURRENT ADDRESS
  • WHEN WERE YOU BORN, JUST TURNED 22 AT THE TIME OF THIS ACCIDENT?
  • WHERE WERE YOU LIVING AT THE TIME OF THE ACCIDENT?


JOB AT THE TIME OF THE ACCIDENT

  • AT THE TIME OF THE ACCIDENT YOU HAD A JOB?
  • YOU WERE WORKING FOR A FAMILY RUN BUSINESS?
  • YOUR ROLE IN THE BUSINESS WAS TO DRIVE THE NURSES WITHOUT LICENSES TO AND FROM THE HOSPITALS?
  • YOU DROVE THE HIS TRUCK FOR THAT, THIS TRUCK WAS NOT YOUR PERSONAL VEHICLE ?
  • DID YOU TAKE ANY SPECIAL DRIVING CLASS FOR THAT JOB?
  • DID YOU EVER HAVE A JOB AS A DRIVER BEFORE THIS JOB WITH YOUR DAD’S BUSINESS?

HOURS BEFORE THE ACCIDENT

  • WHAT TIME DID THIS ACCIDENT TAKE PLACE?
  • WHAT DID YOU DO THAT EVENING BEFORE THE ACCIDENT?
  • YOU WERE TO DRIVE A NURSE TO HARBOR HOSPITAL ?
  • WHAT TIME DID YOU LEAVE YOUR HOUSE?
  • HOW WERE THE ROADS?
  • SNOW ON THE GROUND, ICE ON THE GROUND, SNOWING D 14?
  • GOING SLOWER BECAUSE OF THE WEATHER?
  • MOST DIRECT ROUTE TO THE HOSPITAL, MAIN ROADS?


ON THE WAY BACK

  • AFTER YOU DROPPED OFF THE NURSE, DID THE ROADS GET WORSE, BETTER OR STAY THE SAME?
  • SNOW ON THE GROUND, ICE ON THE GROUND, SNOWING D 14?
  • DID YOU TAKE THAT SAME DIRECT ROUTE HOME ON THE MAIN ROADS?
  • YOU TOOK A SHORT CUT HOME D 12, 14?
  • WHAT ROADS DID YOU TAKE ON YOUR SHORT CUT?
  • THE ROADS YOU TOOK HOME WERE NOT HIGHWAYS?
  • THEY WERE RESIDENTIAL ROADS?
  • WERE THEY SIDE STREETS ?
  • YOU TOOK A DIFFERENT ROUTE HOME TO GO TO A FRIENDS HOUSE TO PICK UP SOME CLOTHES D 14?
  • THOSE SIDE ROADS WERE WORSE THAN 97 AND 695 D 16?

POINT PLEASANT ROAD

  • BEFORE THE NIGHT OF THIS ACCIDENT YOU WERE ON PP BEFORE?
  • YOU KNEW IT WAS ONE LANE IN AND ONE LANE OUT?
  • THERE WERE BENDS AND CURVES IN THE ROAD?
  • BEFORE THE ACCIDENT DID YOU SLIP ON ICE D17?
  • WHAT IS THE SPEED LIMIT ON PP ROAD?
  • WHAT SPEED WERE YOU TRYING TO MAINTAIN ON PP ROAD ?
  • BEFORE YOU GO TO THIS BEND YOU HAD BEEN TRAVELING 20 MPH AND SLIPPED ON THE ICE?
  • YOU SLOWED DOWN THEN PICKED BACK UP TO 20 BEFORE THIS ACCIDENT?
  • WHAT WAS YOUR SPEED WHEN YOU HIT THIS BEND 20 MPH D, 21?
  • WHAT HAPPENED WHEN YOU GOT TO THAT BEND GOING 20 MPH ?
  • YOU CROSSED OVER THE DOUBLE YELLOW LINES?
  • THE FRONT OF YOUR TRUCK HIT HIM HEAD ON ?
  • THE IMPACT WAS ON HIS SIDE OF THE ROAD?
  • WERE YOU ABLE TO TALK TO HIM AFTER THE ACCIDENT?
  • WHAT WAS HE DOING IN THE CAR AFTER THE ACCIDENT?
  • DID YOU SEE ANY BLOOD ?
  • DID ANYONE ELSE STOP BY THE SCENE?
  • WHO CALLED ERNESTO’S GIRLFRIEND?
  • YOU WERE AT THE SCENE OF THE ACCIDENT FOR A WHILE ?
  • WAS IT SNOWING WHILE YOU WERE AT THE SCENE?
  • DID YOU SEE THE ICE ON THE GROUND THAT YOU SLIPPED ON IN THE ROADWAY?

POLICE REPORT IMPEACH

WEATHER INFORMATION IMPEACH

Back to Sample Trial Materials
Back to Attorney Help Center