California Wrongful Death Case - Discovery; Depositions

Immediately After Accident
• Name all persons you spoke with at scene of accident? (This is assuming that the driver of your vehicle in the wrongful death accident was either deceased at the scene or incapacitated.
• (Note: the other attorney will do a thorough examination of every conversation you had or overheard at the accident scene).
• Name all persons who witnessed the accident.
• Name all persons who made statements at the scene of the accident.
• Name all persons who heard any statements made by any individual at the scene of the accident.
• Except for expert witnesses, who may have knowledge of the accident?
• Name anyone who said anything at the time of the accident and as to each:
o Name/ address/ telephone number
o What you said
o What they said
 Plaintiff
 Your Passenger(s)
 Plaintiff Passenger(s)
 Witness(s)
 Police officer
 Anyone else
• Who called the police?
• How long did it take for the police to arrive?
• What did you tell the police?
• What did the other party tell the police?
• What did the witnesses tell the police?
• What did anyone else tell the police?
• How long were you at the accident scene from the time of the accident until you left?

Investigation; General
• Please state the Name/ Address/ Phone number of any person who witnessed events occurring immediately before, during and after the accident.
• Have you or anyone acting on your behalf interviewed any individual concerning the accident. ?
• Have you or anyone acting on your behalf obtained a written or recorded statement from any individual concerning the accident?
• Do you or anyone acting on your behalf know of any photographs, films, or videotapes depicting any place, object, or individual concerning the accident. (Number of photographs or fee of film or videotape; date taken; name/address/ phone number of person taking; name address phone number of each person who has original copy)?
• Do you or anyone acting on your behalf know of any diagram, reproduction or model of any place or thing (except for items developed by expert witnesses) concerning the accident?
• Have you or anyone acting on your behalf inspected the scene of the accident of the wrongful death case?