California Wrongful Death Case - Discovery; Depositions

Accident Scene, Vehicles
• Describe the route that you followed from the beginning of your trip to the location of the accident where the wrongful death occurred.
• State the location of each stop, other than routine traffic stops, during the trip leading up to the accident.
• Describe the direction in which parties were traveling immediately prior to accident?
• Do you know of any malfunction or defect in any vehicle, which may have contributed to the accident?
• What was the nature, dimensions, color, and other characteristics of vehicles and other objects involved in the accident (again, these kinds of questions are objectionable because they are compound. However, this area will be covered by opposing counsel).
• Were your headlights on?
• Were Defendant's headlights on?
• Where were you going just before the accident?
• Was anything distracting you or decedent immediately preceding the accident ?
• Within the last ten seconds preceding the accident, what was decedent doing?
• What was other party doing when you first saw him?
• How far from the other party were you, when you first realized you were in peril of an accident?
• Where was other party when you first realized you were in peril of an accident?
• What was the color of your traffic light when you first saw other party?
• What was the color of your traffic light when you collided with other party?
• Describe the nature, length, and direction of any skid marks left by the vehicles?
• Where were the vehicles when you first saw other party's vehicle?
• How fast were you going when you first saw the other party's vehicle?
• How fast was other party going when you first saw other party?
• Was anything distracting you or decedent just before you first saw other parties vehicle?
• What evasive action did decedent take to avoid the accident?
• How long after you saw the other party did decedent apply brakes?
• On what part of each vehicle did your vehicle and the other party's vehicle make contact?
• What was the nature of the damage to each vehicle?
• What was the location of the vehicles at the moment of collision?
• What was the location of the vehicles following the collision?