“Sudden Stop” question checklist

When a lawyer prepares to take a deposition, he or she usually has an outline or checklist of topics to cover. Depositions in lawsuits based on car accidents usually begin with broad general topics, 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 lawyer might ask in a deposition of a driver who caused a car accident by rear-ending a car that was stopped in front of it. It is most likely that these types of questions would be used by your personal injury lawyer in a deposition of a defendant who is claiming, as a defense, that you were responsible for the car accident because you came to a “sudden stop” in front of him or her. However, since lawsuits involving car accidents frequently involve a counterclaim to the complaint, it is possible that some of the items here may apply to either party, so they could also be used by a defense lawyer who is deposing you about your car accident.

  • How fast were you going immediately prior to perceiving my client’s car stopped in front of you?
  • How far apart were the cars when you made that perception?
  • How many feet separated the cars?
  • How many car lengths apart were they?
  • What is your estimate as to the length of a car?
  • What was the highest speed you attained at anytime through the one mile proceeding the accident?
  • You said that you applied your brakes after perceiving our stopped car.
  • How did you apply the brakes?
  • Did you apply the brakes hard, soft or medium?
  • Did the brakes slow the car down prior to impact?
  • What was the speed of your vehicle upon impact?
  • Did you skid?
  • Did you leave skid marks?
  • How long were the skid marks?
  • Did you pump your brakes or apply steady pressure?
  • Did your vehicle have anti-lock brakes?
  • Was the anti-lock mechanism activated?