Depositions
g. Was his turn signal on? h. Mirrors. What mirrors did his vehicle have? Did he check any of them before making his turn? If so, which ones? What did he see when he checked them?
i. Did you know in advance that you wanted to turn onto ~ road? How did you know this?
j. In your opinion, who had the right-of-way? Why?14
13. Point of Impact. In relation to: curb lines, lane lines, shoulders, center of intersection, etc.
14. Area of contact on all involved vehicles. Which vehicle struck which.
15. Post-collision events. Resting position of involved vehicles.
16. All conversations at scene (whether he participated in or merely overheard them). If the client will testify that he accused the tortfeasor of shoddy driving, see if the tortfeasor will confirm this. Ask him how he responded. threatening?
Also:
17. Post-scene conversations. Cover all other than those with counsel.
14 You might be able to prove that he acted or failed to act based on a misunderstanding of the rules of the road.
18. Roadway post-collision. a. Skid marks. Length, width, from which vehicle. b. Fluid in road. Source. c. Debris in road. Source. d. Pavement gouges. e. Damage to property (e.g., sign posts, trees, bushes).
19. Photos/Images. Find out if they fairly and accurately depict...
20. Language. If it’s a big impact, see if you can get
him to call it a “crash.” If so, casually loop the word “crash” into other questions.
21. Witnesses. a. Names, addresses, phone numbers. b. When did you learn of the witness? c. How was the witness found? d. What is his understanding of what the witness saw? Where was the witness standing in relation to ~ ?
was the client rude, mean,
e. Any relationship to the witness? f. Any post-scene discussions with the witness? Why? What was said by each person involved?
22. Investigators. Did any come to the scene? Identify. If so, what did each do?
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