California Wrongful Death Case - Discovery; Depositions

Prior Accidents
• Decedent been driver in prior auto accident?
• Where, when, circumstances, injuries, settlements, law suits?
• What is decedent's driving experience?

Course and Scope
• At time of accident was the decedent acting as an agent or employee for any person or entity?
o The name address and phone number of that person/entity.
o A general description of his duties.
o What your duties specifically were on the day of the accident?

Physical/Mental Condition (Wrongful death Accident)
• Did decedent have any medical condition, at any time, which would, in any way potentially effect or impair his ability to drive?
• Did decedent ever have had any medical condition, at any time, which, in any way temporarily or permanently effect vision?
• Did decedent consume alcohol within 24 hours of accident?
• Did decedent consume marijuana within seven days of the accident?
• Did decedent consume prescription drug within 24 hours of the accident?
• Did decedent consume non-prescription within 24 hours prior to the accident?
• How many hours sleep did decedent have on the night prior to the accident?
• How many meals had decedent eaten on the day of the accident (describe time and kind)?
• How far had decedent driven on the day of the accident?
• How far did decedent still have to drive on the day of the accident?
• From the time decedent got up on the morning of the accident until the accident, describe any physical activity in which he engaged?
• Just before the accident were decedent physically fatigued?
• Just before the accident was the decedent mentally fatigued?
• Did the decedent have any emotional or relationship problems troubling him just before the accident?

Felony Convictions
• Have you ever been convicted of a felony? For each conviction state:
o City and state where convicted
o Date of conviction
o Offense
o Identity of court you went before

Ownership of Vehicle
• Who was the owner of the vehicle decedent were driving (Name/ Address/ Phone number)?

Property Damage
• Was the vehicle you were driving damaged in the accident?
o If repaired, repair costs
o If not repaired, estimated damages