Auto Accident Deposition Victim Questions

Most of the lawyers in our office were defense lawyers who represented big companies and insurance companies against victims. We have done a complete 180 degree turn: our law firm ONLY represents personal injury victims.

This is an example deposition outline we used when we were defense lawyers.  Sprinkled in this is some information for victims about these questions.

This gives you sample deposition questions for a plaintiff in a car accident to prepare you for the types of questions you may be asked.  Whether you are a plaintiff or a defendant, this outline serves as a valuable resource for anyone involved in a car accident lawsuit, providing clarity and confidence as you navigate your legal journey.

  • Plaintiff (example deposition of a plaintiff in a car accident case)
  • Plaintiff (example deposition of a plaintiff in a truck accident case)

Example Deposition Questions Outline

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.

Do You Need a Lawyer?

If you are about to be deposed, it is probably too late to get our law firm involved. But who knows? If you want to discuss your potential claim with an experienced Maryland accident attorney, call 800-553-8082 or get a free no obligation case consultation.

More Information

Client Reviews
They quite literally worked as hard as if not harder than the doctors to save our lives. Terry Waldron
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
Hopefully I won't need it again but if I do, I have definitely found my lawyer for life and I would definitely recommend this office to anyone! Bridget Stevens
The last case I referred to them settled for $1.2 million. John Selinger
I am so grateful that I was lucky to pick Miller & Zois. Maggie Lauer
The entire team from the intake Samantha to the lawyer himself (Ron Miller) has been really approachable. Suzette Allen
The case settled and I got a lot more money than I expected. Ron even fought to reduce how much I owed in medical bills so I could get an even larger settlement. Nchedo Idahosa
Contact Information