A plaintiff’s deposition typically focuses on four areas. These are (1) the plaintiff’s back- ground, (2) the circumstances of the incident for which the plaintiff is now suing, (3) the plaintiff’s alleged injuries and medical treatment as a result of the accident, and (4) the claimed impact of such injuries on the plaintiff’s daily life, habits, and routines. Below is a non-exhaustive list of common questions from each category that you can expect to face during your deposition:
Residential address history, Employment history, Educational History.
CIRCUMSTANCES OF THE INCIDENT
Where the incident transpired. When the incident took place (i.e. date and time, what day of the week, etc.). The physical appearance/layout of the scene (at the time of the accident and currently). Weather and lighting conditions the sequence of how the incident unfolded. What you were doing in the moments immediately before and after the incident. Whether you sought medical attention following the accident. Whether you spoke with anyone regarding the incident, at the scene or otherwise. Whether you are aware of any witnesses to the incident. Whether police and/or medical personnel responded
YOUR INJURIES AND TREATMENT What injury or injuries you claim to have suffered as a result of the incident/accident in question Any pre-existing health conditions that you contend were aggravated as a result of the accident Information regarding all doctors and other medical providers who treated you specifically for the injuries you claimed to have sustained in the case in question The timeline of your symptoms (i.e. whether the symptoms were felt immediately or developed over a period of time, the duration of each symptom, whether the symptoms have improved/worsened/remained the same over time, whether you are experiencing any symptoms currently, etc.) The amount of time that elapsed between the happening of the incident and the time you first sought medical attention Any gaps in your medical care (and if so, the reasons for such gaps and how long they lasted) Total costs of medical care (and whether out-of-pocket vs. covered by insurance, etc.)
Whether you missed any time from work as a result of the incident and/or injuries (and if so, (1) the length of time and the total amount of any lost wages you may be claiming for that period, and (2) whether you anticipate missing additional time from work in the future)) Whether you missed any time from school (if applicable) The manner in which your day-to-day activities have been affected Whether there are certain things you do less frequently now (or with less skill or intensity, etc.) Whether there are things you can no longer do at all Whether family and/or personal relationships have been affected.
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