California Wrongful Death Case - Discovery; Depositions

DEPOSITION QUESTIONS: WRONGFUL DEATH
(Note: The following deposition questions assume you were a right front seat passenger in a vehicle being operated by the person who was killed in the accident. The decedent is a relative of yours. You have filed a wrongful death case against the driver of the other vehicle).

Personal
• Please state your name.
• State all names used in past and dates you used them.
• What were your residence addresses, last five years and when you lived there?
• What is your martial status?
• What is your educational background?
• Name & location of each school or vocational institution attended, starting with High School
• Dates of Attendance
• Highest grade level completed
• Degrees/diplomas received
• Who is your present employer?
• Name
• Address
• Job Description
• Inclusive dates of employment
• Who were your former employers, last ten years?
• Name
• Address
• Job Description
• Inclusive dates of employment

License/Insurance
• May I see your driver's license? (In a wrongful death case, or any other personal injury case they will ask you for your license. It may contain relevant information, such as whether or not you wear glasses).
• (The attorney will read all info on driver's license into record and have you agree it is correct).
• Please identify all states in which you have held driver's license.
• Has license ever been denied, revoked or suspended?
• At time of accident, did you have any other permit or license for operation of motor vehicle?
• At time of accident, did you own a vehicle?
• At time of accident, were you insured?
• Kind of coverage
• Name of insurance company
• Name/ Address/ Phone number of each named insured
• Limits of coverage for each type of coverage contained in the policy
• Do any reservation of rights or controversy or coverage dispute exists between you and the insurance company?
• Are you self-insured under any statute?
• Have you ever been denied auto insurance or had your auto insurance cancelled?
• Did you receive driver's education in school?
• Has a court ever ordered or otherwise authorized you to attend any driver's class or classes?