California Wrongful Death Case - Discovery; Depositions

Accident Scene, General
• State the location of the accident of your wrongful death suit.
• State the date of the accident.
• State the time of accident.
• What were the general weather conditions at the time of the accident?
• What was the topography of the area in which accident occurred? (Note: this question is objectionable because it is too general, broad and remote. However, you may be asked specific questions about the general topography of the area).
• What was the location of any pedestrians at time of accident?
• What was the nature and location of any traffic signs or signals in the area of the accident. (Again, this question is too general. Throughout this analysis, I am including questions that are too general in nature; however, expect questions in these areas).
• Was the road straight or curved?
• What was the general condition of the road surface?
• What was the speed limit where you first saw the other party?
• On a scale of one to ten, one being extremely light and ten being extremely heavy, how would you characterize traffic conditions at the scene of the accident?

Obstructions to Vision
• What was the location of the sun at the time of the accident?
• Describe the lighting conditions at the time of the accident?
• What was the nature and extent of any permanent obstructions to you and decedent's visibility in the area (buildings, trees, etc)?
• Were any vehicles obstructing your or decedent's visibility at the time of the accident?
• Was anything obstructing your or decedent's vision at the time of the accident?
• Was anything obstructing the traffic signs or signals in the last 200 yards before the accident?
• Was anything obstructing the traffic signs or signals at the scene of the accident?
• Was anything obstructing the traffic signs or signals in the last 200 yards before the accident?
• Were there any conditions impairing your or decedent's ability to see outside the vehicle
o Fogged or frosted windshield or side windows
o Ineffective windshield wipers
o Passengers or objects blocking the driver's vision
o (If accident occurred at night) Existence of street lights or other lighting sources