Direct-Examination Outline of Plaintiff

(Injury Victim)

1. What is your name?

2. How old are you?

3. Are you married?

4. How long have you been married?

5. Do you have any children?

6. What do you do for a living?

Before the Accident

One thing that plaintiffs' lawyers miss time and time again: painting a clear picture of the plaintiff before the accident is as important as the after.

7. Tell us a little bit about what your life was like before the accident.

8. How were things going with your job?

9. How were things at home?

10(a). What was going on at your house?

10(b). Did you have economic pressures on you before the accident?

The Accident Scene

10(c). Do you recall suffering an injury on March 10, 2011?

10(d). Do you know what day of the week March 10, 2011 was?

11. What happened?

A. Positioning
B. Point of Impact
C. Pinned
D. Force (dented car)

12. What did the defendant do while you were pinned between the car and the Bobcat?

13. While you were pinned, what was the pain like?

14. How long were you pinned between the Bobcat and the car?

15. How long did it take for the paramedics to arrive?

16. What did the paramedics do for you?

17. Did they give you pain medication?

18. What did they tell you about your injury?


19. Did the paramedics take you to the hospital?

20. Which hospital?

21. What did they do for you in the hosptial?

22. What did they tell you your injuries were?

23. Were you released from the hospital?

24. What did they tell you when they released you?

25. Were you able to walk out of the hospital on your own power?

26. The accident occurred on a Saturday? Describe the rest of your weekend?

Dr. Herron’s March 12, 2008 Visit

27. When did you go back to the doctors for this injury? (Injury was on a Saturday.)

28. Who did you go see?

29. What did they do for you at Dr. Herron’s office?

30. What were you told about your injury at Dr. Herron’s office?

Post March 12 to Surgery

31. Can you tell us about the period between you March 12, 2008 visit to Dr. Herron’s office and April 2, 2011? What was your life like and how were you injuries?

32. Did you begin to develop new problems with you left knee?

33. What as the problem?

34. What did the doctors do to treat this inflamation with you knee?

35. Was that surgery on April 12, 2008?

Post Surgery 1 to Surgery 2

36. Can you tell us about the period between you first surgery and June 4, 2011 when you had your second surgery? How were you progressing? Were you working?

37. Did you get a second surgery in June 2008?

38. What was that surgery for?

39. Who did the surgery?

40. What were you told after that surgery?


41. Did you see any other doctors after your surgery?

42. Who did you see?

43. What did they do for you?

44. During this time period, did you expect to go back to work as a mechanic?

45. What were your plans?

46. What did they tell you to do?

Missed Work

46. During the time you are seeing Dr. Johnson, are you working?

47. Was not working a concern to you?

48. What did you tell you doctors about working?

Going Back to Work

49. When did you go back to work?

50. How did it go?

51. How are things going now?

51(a). What difficulties are you having?

52. How were you able to make more money in 2002 after the accident than in 2000, the year before the accident?

53. What are your work conditions like with you co-workers before the accident?

54. What are you work conditions like now?

55. Exhibit Q. What are these? Who wrote them?

56. How does this make you feel?

57. Do you think you will be able to continue as a mechanic at Dole Chrysler making the kind of money you have been making?

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