Auto Accident Deposition Victim Questions

I. Personal Background

1. Basic Information
   • Full name, current address, and phone number.
   • Date and place of birth.
   • All addresses for the past 10 years, with dates of residence.
2. Education
   • List all schools attended, degrees obtained, and graduation dates.
   • Any additional training or education received after leaving school, including certifications and special courses.
3. Family Background
   • Marital status (married, single, divorced, widowed).
   • Names and ages of children.
   • Current living situation: Who lives with you now? Who lived with you at the time of the accident? (Include any changes in living arrangements since the accident.)
4. Health and Medical Background
   • General health status before the accident, including any chronic conditions.
   • List of any medications taken regularly before the accident.
   • Any previous injuries or surgeries, especially those related to the current injury.
   • Current ability to answer questions, including any cognitive or memory issues.
5. Employment History
   • Detailed list of the last several jobs held, including job titles, dates of employment, and reasons for leaving.
   • Detailed description of current job: duties, physical requirements, hours, pay, supervisor, and coworkers.
   • Any time missed from work in the last five years: reasons and duration.
   • Any changes in job performance or ability to work since the accident.
6. Criminal Background
   • Any convictions of a crime, including dates, nature of the offense, and penalties. (This is unlikely to hurt your case but talk to your lawyer in advance about these to develop a strategy.)
7. Injury/Civil Claims Background
   • Details of any previous lawsuits filed, including dates, nature of the claims, and outcomes.
   • Details of any other claims, such as workers’ compensation, including dates and outcomes.
   • Potential biases towards any party involved in the current case. Prior relationships (passengers) and what happened at the scene, if applicable.

II. How the Car Crash Happened

1. Accident Details
   • Exact time, date, and day of the week of the accident.
   • Location of the accident, including street names, intersections, and landmarks.
   • Weather conditions at the time of the accident (rain, snow, fog, clear, etc.).
   • Traffic conditions at the time of the accident (heavy, moderate, light).
2. Travel Details
   • Where were you coming from and where were you headed?
   • Purpose of your trip.
   • Route taken to the accident location.
3. Traffic Control Devices
   • Presence and status of any traffic control devices, such as traffic lights, stop signs, yield signs, and lane markings.
   • Whether any of these devices were malfunctioning or obscured.
4. Actions of Each Driver
   • Detailed account of your actions leading up to the accident (speed, lane changes, signals used, etc.).
   • Detailed account of the other driver’s actions as observed by you.
   • Distance between the vehicles when you first saw the other vehicle.
   • Position of both vehicles on the roadway at the time of the accident.
   • Speed of both vehicles at the time of the accident.
   • Point of collision on the roadway.
   • Specific areas of the vehicles that collided (e.g., driver’s side fender, passenger side door).
   • Final resting positions of both vehicles after the collision.
5. Post-Accident Interaction
   • Conversations with the other driver(s) at the scene.
   • Any admissions of responsibility by the other driver.
   • Description of your physical state and actions immediately after the collision.
6. Physical Impact
   • Description of what happened to your body inside the vehicle during the collision (e.g., body parts that hit parts of the car).
   • Any immediate physical symptoms or injuries noted.
7. Vehicle Damage
   • Description of the damage to your vehicle.
   • Description of the damage to the other vehicle(s).
   • Details of vehicle repairs and costs.
8. Witnesses
   • Identification of any witnesses to the accident.
   • Identification of anyone who came to the accident scene within two hours after the accident.
   • Collection of contact information for witnesses.
9. Evidence
   • Availability of photos or diagrams showing the accident scene.
   • Any alcohol or drug consumption in the 24 hours before the accident.
   • Details of any report or witness statement filled out regarding the accident.
10. Fault Determination

• • Factors that you believe prove the other party was at fault.
  • Examination of a sample deposition of a defendant in a similar case.

III. Injuries and Treatment

1. Injuries Claimed
   • Detailed description of all injuries claimed to be caused by the accident.
   • Comparison of current injuries with any pre-existing conditions that may have been aggravated by the accident.
2. Medical Treatment
   • List of all doctors and health care providers seen for treatment of injuries.
   • Symptoms experienced at the scene of the accident.
   • Actions taken immediately after the accident, including whether you got out of the car and walked around.
   • Timeline of seeking medical care and the initial symptoms reported to the doctor.
3. Symptom Progression
   • Description of symptom progression over time, including any improvements or deteriorations.
   • Any gaps in medical care and reasons for not getting treatment during those gaps.
4. Current Symptoms
   • Current symptoms attributed to the accident.
   • Ongoing medical treatment and medications.
5. Medical Bills and Expenses
   • Total amount of medical bills incurred so far.
   • Details of any missed time from work due to the accident, including dates and amounts of lost income.
   • Expected future medical expenses and potential lost income.
6. Impact on Daily Life
   • Detailed description of how injuries have affected day-to-day activities.
   • Activities that can no longer be performed as a result of the injuries.
   • Activities that can still be performed but not as well or as often due to the injuries.
7. Impact on Personal Relationships
   • Impact of injuries on personal relationships, including marriage and family dynamics.
   • Loss or reduction of sexual activity.
   • Loss of enjoyment of activities previously enjoyed together, such as vacations and hobbies.

This detailed outline should help ensure all relevant topics are covered during the deposition, providing a comprehensive understanding of the case from the plaintiff’s perspective.