Direct-Examination of Plaintiff's Spouse

The most important witness in a personal injury case can be the victim's spouse or significant other.  Why?  Because the spouse can carry the ball on pain and suffering in a way that the victim cannot. The same suffering that is poignant coming from the spouse can come off a whining if it came from the plaintiff.   

If you are getting ready for trial or moot court in a personal injury case, we have a ton of weapons for you: 

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?
    One thing that plaintiffs' lawyers fail to do: paint a clear picture of the plaintiff before the injuries.  This is as important as after. Jurors may assume that the plaintiff was always the type of person who is hurt... they can't imagine anything else because that is all they have seen.
  • 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?
  • WERE YOU ABLE TO REGULARLY ATTEND CHURCH?  This is a big deal to many jurors.  If your clients regularly attended church, you want to bring that out in the direct examination.  
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

The key here is real human examples that connect the plaintiff to the jury. They have to be relatable and sincere.

  • 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?

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They quite literally worked as hard as if not harder than the doctors to save our lives.
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Ron helped me find a clear path that ended with my foot healing and a settlement that was much more than I hope for. Aaron Johnson
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