Personal Background

1. Name, address, telephone number, date of birth.

2. Your residential addresses for the past 10 years or so.

3. Your educational background:

• schools and degrees , and
• education and training you have received since you left school.

4. Your family background:

• marital status
• number of children, and
• living situation (who lives with you now, and who lived with you at the time of the accident).

5. Your health and medical background:

• other injuries and health issues that existed before this accident
• other injuries and health issues that you’ve experienced since this accident
• any chronic health problems, and
• doctors you have seen during the last 10 years (or so) and types of treatment you have received (especially treatment on any parts of your body that were injured in this accident).

6. Employment background:

• your last several jobs
• your current job (duties, physical requirements, hours, pay, supervisor, co-workers), and
• whether you have missed time from work during the last five years (or so)? If so, how much time, and why?

7. Criminal background:

• have you ever been convicted of a crime?

8. Injury/civil claims background:

• have you ever filed any lawsuits?
• have you ever made any other kinds of administrative claims, such as workers compensation claims?

How the Accident Happened

Typical car accident deposition questions on how the accident happened include:

1. Time, date, day of week, and location of the traffic accident.

2. Where were you coming from and where were you headed?

3. What were the weather conditions?

4. What were the traffic conditions?

5. Were there any traffic control devices, such as traffic lights, stop signs, other signage, lane markings, etc. involved?

6. Exactly what each driver did and when. Be prepared for specific questions about times and distances. For example:

• How far was the other car from you when you first saw it?
• Where was the other car on the roadway at the time?
• How fast were you going?
• How fast was the other car going?
• Where on the roadway did the cars collide?
• What areas of the vehicles collided (i.e. driver's side fender, passenger side door)?
• Where did the cars come to rest?

Tip: If you don't know the answers to these (or any) questions, don't guess.

7. Did you speak to the other driver after the accident and, if so, what did each of you say? Did either of you admit responsibility for causing the accident? (Remember, be careful what you say at the scene of a car accident.)

8. What happened to your body inside the vehicle when the collision occurred? Did any part of your body hit any part of the car?

9. What happened to your car after it was hit?

10. What physical damage did each car have? Was your car repaired? How much did the repairs cost?

11. Who were the witnesses to the accident? Who came to the accident scene?

12. Do you have any photos or diagrams that show the accident scene? (You may be asked to draw a (non-scale) diagram of the accident scene showing how the accident happened.)

13. Did you drink any alcohol during the 24 hours before the accident?

14. Do you know of any reports generated in connection with the accident? (such as a police report)

Your Injuries and Treatment

Typical car accident deposition questions related to your injuries and treatment include:

1. What injuries do you claim were caused by this accident?

2. Did you have any health conditions before the accident that you contend were aggravated (made worse) by the accident?

3. What doctors and other health care providers have you seen for treatment of your injuries?

4. What symptoms did you have at the scene of the accident? Did you get out of your car and walk around at the scene?

5. When did you first get medical care after the car accident? What did you tell the doctor about your symptoms at that first visit?

6. What were your symptoms over time? Did your symptoms any get better? Which symptoms and when?

7. If there were any gaps in your medical care (periods of several weeks or more that you did not get any treatment) why did you not get treatment?

8. What symptoms, if any, do you still have that you attribute to this accident?

9. How much have you incurred in medical bills so far?

10. Have you missed any time from work as a result of this accident? How much? When? What amount of lost income are you claiming?

11. Do you claim that you will miss work or lose income in the future as a result of this accident? If so, explain.

12. How have your injuries affected your day-to-day activities?

• What are the things that you cannot do at all as a result of your injuries?
• What are the things that you cannot do as well (or as often or for as long) as usual as a result of your injuries?

13. How has your injury affected your personal relationships, i.e. your marriage? Loss or reduction of sex? Loss of enjoyment of other activities together? Loss of vacations? Loss of other opportunities?