Depositions
Maryland Orthopedics, P.A. Board Certified Orthopedic Surgeons
Ellicott City ♦ 3570 St. Johns Lane 410-461-9500 Laurel ♦ 545 Main Street 301-776-2000
Owings Mills ♦ Physicians Pavillion, 10085 Red Run Blvd. 410-363-0777 Frederick ♦ 75 Thomas Johnson Drive 301-663-0009 WHEN QUALITY COUNTS
At Maryland Orthopedics PA, our physicians and staff pride themselves on their expertise with Personal Injury cases and work-related injuries covered under Worker’s Compensation. We understand the special challenges presented by industrial injuries and can provide many services such as x-ray, medications, neurological testing and physical therapy in house.
Most Appointments within 24 Hours Monday-Friday
Raymond D. Drapkin, M.D. William J. Launder, M.D. Kevin E. McGovern, M.D.
Michael A. Franchetti, M.D. Mark A. Cohen, M.D. Susan J. Liu, M.D.
Arthur E. Kurlanzik, M.D. ♦ Neurological Services
18. Rear-end collisions generally. Ask: “How did you apply the brakes (gently, normally, slammed, etc.)? Why? How much time passed between application of brakes and impact? Were your brake lights working? How do you know?”
19. Rear-end collision -- at impact the client was
stopped. If the client will testify that his car moved forward as a result of the impact, how far did it move? Did his vehicle leave skid marks left at the scene? If he will testify that there were none, did the impact temporarily jar his foot off of the brake?
20. Rear-end chain reaction collisions. If you represent the first vehicle in the line: “How many impacts did you feel? How much time between each impact?” If more than one, review the sequence of impacts.
21. Intersection collisions with traffic light. a. Did the client and tortfeasor enter the intersection from a stopped or moving position? Which vehicle entered first?
b. Traffic light. What was its sequence (try to discover this from first-hand observation or through the appropriate local government agency before the prep session)? What color
18 Trial Reporter / Winter 2011
was the light for each participant in the collision before he or she entered the intersection? How far away was he when he first looked at the light? When he next looked at the light? When he last looked at the light (if he looked at it a third time)? Compare your client’s perception of the light sequence with what your research reveals.
22. Lane change collisions. If the client changed lanes, did he turn his head to look before doing so? Did he check his mirrors? If so: Which one(s)? How many times? In what sequence?
23. Stick (manual/manumatic/tiptronic) v. automatic. If not an automatic, explore what gear your client was in at all critical junctures, and why.
24. Last clear chance. If this doctrine is on your radar, you’ve undoubtedly taken a tough case. Recall that Maryland requires a fresh opportunity for the tortfeasor to avoid the bad event whereas the District does not. Compare MPJI-Cv 19:14 with D.C. Std. Civ. Jury Instr. No. 5-18.
25. Evasive actions. Did the client take any? Why/why not?
26. Position of vehicles at impact and rest.
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