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Sorry just got out of bed and this is too much to process. However, I would tell you to break up your questions rather than compound them. You told your med providers about all injuries? What injury was from D1? D2? Why didn't you discuss with your med providers D2? Didn't you say you told them about all injuries before? Look at the photo of your rear, can you explain why no damage? Yet you claim injuries?
Is Plaintiff claiming injury from the rear-end collision itself or is Plaintiff claiming that the rear-end collision contributed to the occurrence of the collision with D2, i.e., that rear-end collision caused plaintiff’s vehicle to enter into D2’s path of travel?
I agree with senior associate 1. But also, Give the guy a chance to talk about the accident by giving an open ended question. So “what happened at the time of the accident?” He’ll probably focus on the hard passenger side accident a lot and may not even mention the rear hit much. Ask all the questions about the harder hit first, so as to box him in. For example, can you describe the impact on the passenger side? Minimal, moderate, heavy? He’ll probably say heavy. How did your body move as a result of the passenger side impact inside the car? Did you make contact with anything inside the car? Did the airbags deploy? Which ones?
Then you ask about your client’s hit. At this point, plaintiff will probably remember he needs to say how terrible your guy was so he can make some more $$$. At that point, he’ll likely say oh, the rear hit was also heavy. And that’s when you undermine his credibility.
You can keep going with photos (which I always show after the plaintiff has described the accident)
Agree with this, and it’s applicable to the medical record questions. Start general, skip around lines of questioning, and save the pointed questions for later so you get good general admissions without them realizing where you’re going.
I’m having a hard time picturing that collision. Was it a four-way intersection and P had a left green arrow? And your client was turning left behind P and hit him?
If P didn’t see the guy running the red light, how was your client supposed to see the guy running the red light?
Just because your client’s car collided with P’s car doesn’t mean your client caused the collision. D2 caused your client to collide with P.
Don’t go at P directly with your questions. Establish there was no way for P to see the guy running the red light. Then show there was no way for your client to see the guy running the red light. Which cars were sedans and which cars were SUV’s? Where were the lines of sight? Was there a line of cars turning left in the opposite direction that made it harder to see D2? P doesn’t know and can’t answer what your client saw. So use what P had to say about why he couldn’t have prevented the collision to show why it was even harder for your client to prevent it.
I know you wanna do a good dep. But the point of deps are summary judgment. Plaintiffs’ deps aren’t particularly meaningful for SJ. You basically get two bites at the Apple. There’s the fact that your client did not cause the collision. And there’s also no evidence that your client caused the injuries.
If I’m understanding correctly maybe something like this: “in all interactions with your medical providers, where you forthcoming about all circumstances you deemed relevant to your injuries, including any impact from the rear? … I ask to clarify the extent to which the rear impact contributed to your reported injuries, considering the absence of mention in medical records”….
How do I ask, you would be honest with your med providers of all matters to which you deem important and having contributed to your injuries..my point I want to raise for the record is that the rear impact was so minimal, it clearly did not add to his injuries otherwise he would told med providers I got hit from the side AND the back..
This is perfect thanks! I wish law school focused more on these type of hands on experience rather than philosophical questions.
F