Plaintiff Attorney Legal Information Center(Defendant Driver)
BACKGROUND
- FULL NAME AND CURRENT ADDRESS
- WHEN WERE YOU BORN, JUST TURNED 22 AT THE TIME OF THIS ACCIDENT?
- WHERE WERE YOU LIVING AT THE TIME OF THE ACCIDENT?
JOB AT THE TIME OF THE ACCIDENT
- AT THE TIME OF THE ACCIDENT YOU HAD A JOB?
- YOU WERE WORKING FOR A FAMILY RUN BUSINESS?
- YOUR ROLE IN THE BUSINESS WAS TO DRIVE THE NURSES WITHOUT LICENSES TO AND FROM THE HOSPITALS?
- YOU DROVE THE HIS TRUCK FOR THAT, THIS TRUCK WAS NOT YOUR PERSONAL VEHICLE ?
- DID YOU TAKE ANY SPECIAL DRIVING CLASS FOR THAT JOB?
- DID YOU EVER HAVE A JOB AS A DRIVER BEFORE THIS JOB WITH YOUR DAD’S BUSINESS?
HOURS BEFORE THE ACCIDENT
- WHAT TIME DID THIS ACCIDENT TAKE PLACE?
- WHAT DID YOU DO THAT EVENING BEFORE THE ACCIDENT?
- YOU WERE TO DRIVE A NURSE TO HARBOR HOSPITAL ?
- WHAT TIME DID YOU LEAVE YOUR HOUSE?
- HOW WERE THE ROADS?
- SNOW ON THE GROUND, ICE ON THE GROUND, SNOWING D 14?
- GOING SLOWER BECAUSE OF THE WEATHER?
- MOST DIRECT ROUTE TO THE HOSPITAL, MAIN ROADS?
ON THE WAY BACK
- AFTER YOU DROPPED OFF THE NURSE, DID THE ROADS GET WORSE, BETTER OR STAY THE SAME?
- SNOW ON THE GROUND, ICE ON THE GROUND, SNOWING D 14?
- DID YOU TAKE THAT SAME DIRECT ROUTE HOME ON THE MAIN ROADS?
- YOU TOOK A SHORT CUT HOME D 12, 14?
- WHAT ROADS DID YOU TAKE ON YOUR SHORT CUT?
- THE ROADS YOU TOOK HOME WERE NOT HIGHWAYS?
- THEY WERE RESIDENTIAL ROADS?
- WERE THEY SIDE STREETS ?
- YOU TOOK A DIFFERENT ROUTE HOME TO GO TO A FRIENDS HOUSE TO PICK UP SOME CLOTHES D 14?
- THOSE SIDE ROADS WERE WORSE THAN 97 AND 695 D 16?
POINT PLEASANT ROAD
- BEFORE THE NIGHT OF THIS ACCIDENT YOU WERE ON PP BEFORE?
- YOU KNEW IT WAS ONE LANE IN AND ONE LANE OUT?
- THERE WERE BENDS AND CURVES IN THE ROAD?
- BEFORE THE ACCIDENT DID YOU SLIP ON ICE D17?
- WHAT IS THE SPEED LIMIT ON PP ROAD?
- WHAT SPEED WERE YOU TRYING TO MAINTAIN ON PP ROAD ?
- BEFORE YOU GO TO THIS BEND YOU HAD BEEN TRAVELING 20 MPH AND SLIPPED ON THE ICE?
- YOU SLOWED DOWN THEN PICKED BACK UP TO 20 BEFORE THIS ACCIDENT?
- WHAT WAS YOUR SPEED WHEN YOU HIT THIS BEND 20 MPH D, 21?
- WHAT HAPPENED WHEN YOU GOT TO THAT BEND GOING 20 MPH ?
- YOU CROSSED OVER THE DOUBLE YELLOW LINES?
- THE FRONT OF YOUR TRUCK HIT HIM HEAD ON ?
- THE IMPACT WAS ON HIS SIDE OF THE ROAD?
- WERE YOU ABLE TO TALK TO HIM AFTER THE ACCIDENT?
- WHAT WAS HE DOING IN THE CAR AFTER THE ACCIDENT?
- DID YOU SEE ANY BLOOD ?
- DID ANYONE ELSE STOP BY THE SCENE?
- WHO CALLED ERNESTO’S GIRLFRIEND?
- YOU WERE AT THE SCENE OF THE ACCIDENT FOR A WHILE ?
- WAS IT SNOWING WHILE YOU WERE AT THE SCENE?
- DID YOU SEE THE ICE ON THE GROUND THAT YOU SLIPPED ON IN THE ROADWAY?
More Cross Examination Information for Lawyers and Moot Court Students
- Cross Examination Tips
- Sample Trial Materials (sample trial transcripts, etc.)
- Attorney Help Center (soup to nuts handling of personal injury cases)
- Can you used Defendant’s guilty plea against him at trial?