Questions about statements

When a lawyer prepares to take a deposition for a lawsuit he or she usually has an outline or checklist of topics to cover. In lawsuits based on car accidents, depositions usually begin with broad general topics, and then later get into specific areas that deal with the car accident and relate to liability issues.

The following sample questions are things that a defense lawyer might ask in a deposition about statements that you have made about the car accident. These can include statements made at the scene to the other driver, or to a witness, or to a police officer who arrived at the scene and asked questions. You may also have provided a written statement about the car accident to an investigator.

• Did you have any conversation with anyone on the scene?
• What did you say to the other driver, my client?
• What, if anything, did my client say to you?
• Was anything else said?
• Did my client say anything about the occurrence of the accident?
• What did you say about why the accident happened?
• Did the police come on the scene?
• Did you speak with the police?
• What did you tell them?
• Were you telling them the truth?
• Did you at some time speak with an investigator?
• Did he ask you questions about how the accident took place?
• Did he write out your statement or version?
• Look at Exhibit I, is this your signature?
• What is the date on that document?
• Above your signature, is there some writing?
• Is that writing your handwriting?
• Does it say “I have read the above and it is true and correct?”
• And that is your handwriting?
• And after writing that statement, you signed the document?
• And it was true that you read the statement before you signed it?