General deposition questions

When a lawyer prepares to take a deposition he or she usually has an outline or checklist of topics to cover.

The following sample checklists show some of the general questions a defense lawyer might ask you in your deposition (or your personal injury lawyer might ask the other driver) in lawsuit based on a car accident.

Background questions

How old are you?
What is your date of birth?
How far did you go in school?
Did you complete the 12th grade?
Have you had any further formal education?
Are you married?
What is your date of marriage?
Who do you work for?
How long have you worked for them?
What are your job duties and responsibilities?
Do you have a driver’s license?
When did you obtain your driver’s license?
Has your license ever been revoked?
Are there any restrictions on your license, such as eye glasses?
Were you wearing your glasses at the time of the collision?

Questions about the car accident

Not all of these questions will be appropriate. Some apply only to you, others apply only to the other driver, and still others apply only to the owner of the other car.

What was the date of the accident?
At what time of day did it occur?
What day of the week was it?
Where were you coming from?
Where were you going?
Were you late or in a hurry?
What route were you following?
Were you familiar with that route?
Were you taking medications?
Were there any medications prescribed at the time that you failed to take?
Had you consumed any alcohol within the prior 24 hours?
Were you alone in the vehicle?
What are the names and addresses of the passengers?
What was the make, model, year and condition of the car he was driving?
Who was the owner of the vehicle?
Did the owner know you were driving the vehicle?
Did you have the owner’s permission and consent to operate the vehicle?
Did the driver have your permission and consent to operate your vehicle?
What were the weather conditions at the time of the accident?
Describe the roadway in terms of lanes, shoulders and topography.
What were traffic conditions?
What was the speed limit?
What was your speed prior to braking?
What was your speed upon impact?
What were you doing inside the vehicle just before the accident?
Was your radio on?
Where were you looking immediately prior to noticing that the car in front had stopped?
Were you talking on your cellular phone?
Were you eating or drinking?
Were you talking with your passengers?
What was being discussed?
Were there any pets in the vehicle?
What else, if anything, attracted your attention?
When did you first see the other vehicle?
How far apart were the cars when you first noticed the other vehicle?
Where were other vehicles on the roadway immediately prior to the accident?
Were they in front of you going the same direction?
Were they behind you?
Were they along the side of your vehicle?
Were any cars coming toward you?
Were there any parked cars?
How many cars were stopped at the traffic light?
How many cars were ahead of you?
Were there cars in each of the turn lanes?
Please specify.
What was the time between your first awareness of the other vehicle & impact?
What evasive action, if any, was taken?
Did you sound your horn?
Did you apply your brakes?
Did they take hold?
What caused the accident?
Why did you not see the other car before impact?
Why did you not sound your horn?
Why did you not take evasive action?
Was the sun in your eyes?
Were you distracted by anything?
Did the glare bother you?
Was your vision obstructed by anything?
Did the bushes at the corner obstruct your vision?
Were you looking elsewhere just prior to seeing the other vehicle?

Questions about employment

Where are you employed?
What is your job?
What are your duties and responsibilities?
How long have you worked for them?
Have you held any other positions in that company?
What were your duties and responsibilities in that position?
How long were you in that position?
How long have you been in your present position?
Where did you work before your present employer?
What was your position in that job?
How long did you work there?
Why did you leave?
What was your rate of pay?
What fringe benefits did you have?
What retirement programs, if any, did you have?

Questions about education

You told us that you completed high school.
Do you have any formal education since high school?
Where did you go to college and for how long?
Have you taken any other courses since then?
Have you attended seminars on a regular basis?
Have you published any articles on your trade or profession?
If so, what and when?