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| "...[This] LTF form is
better than I expected. Comprehensive." --- Charlie Sizemore, Tennessee attorney. |
This is a pattern deposition question outline for both plaintiff and defense attorneys, and also their legal assistants, in motor vehicle accident cases. This is the basic, must-have, form in any car or truck negligence case- a checklist of the questions to ask in a deposition of the adverse driver, or at trial. More >>
Generally this form will also be suitable as the basis for deposing the passenger in an automobile, or a witness to the accident. (The questions to the driver regarding what the driver did, can be switched to asking what the passenger or witness say the driver do.)
Because it is useful in examining the adverse driver, it will also be a handy checklist to use in witness preparation, preparing your own client or witness to testify. (After all, if these are things a good lawyer will ask the adverse driver, shouldn't your client be prepared to deal with these questions?) MVA Driver Deposition Checklist
# 2. Motor Vehicle Police Officer Checklist: Interview - Deposition - Trial Testimony. In every bodily injury or death that involves an auto, truck, motorcycle, or highway pedestrian accident there is a police officer involved. Our deposition checklist is not only also a pattern interview checklist -- it is also a trial testimony checklist. Click here to go to the Motor Vehicle Police Officer Checklist: Interview - Deposition - Trial Testimony
# 3. Request to Bring Items to the MVA Driver or Witness Deposition. Whether you represent plaintiff or defendant, when you take the deposition of the adverse driver, or of a passenger, you should consider including a demand that certain items be brought to the motor vehicle accident deposition by the adverse party. Make this little $4.50 form a standard routine. It's an example of why we say that our forms are like having a mentor in a box. Click to go to the Request to Bring Items to the Deposition.
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# 4. Before or After Witness. Interview, deposition, or trial questions checklist. For witnesses who were not riding in a vehicle involved in the motor vehicle accident (MVA), but who saw the occurrence or events leading up to it. And for witnesses who arrived only after the crash, including ambulance, fire, and tow truck personnel.
# 5. Request of Admissions, Plaintiff's, Rear-End MVA. This is specialized for only plaintiffs in rear-end motor vehicle cases. It is a suggested demand for admissions that puts the pressure on the defense. Good ideas for an inexpensive price. Before you take the depo of the adverse driver, if you represent a occupant of a car that was rear-ended, you probably want our Plaintiff's Request for Admissions, Rear-End MVA
# 6. Checklist - Deposition of Truck Driver to Show Company Control of Driver. This checklist is designed for the depositions of either a truck driver or the defendant company's executive, when the deposition is to establish the Company was in control of the Driver at the time of the MVA. An adjunct to the above Driver Deposition Checklist. Used by plaintiff's attorney for questioning. Used by defendant's attorney in preparing the defense witness for a deposition or cross-examination. When a truck is involved, use Checklist - Deposition of Truck Driver to Show Company Control of Driver
# 7. Notice of Taking Deposition of Organization Regarding Control of Driver and Independent Negligence of Organization in MVA. This laundry list form has the specifications you need to give notice of the deposition of an organization regarding its auto or truck driver, and gather all the relevant documents during that deposition. If you get the checklist for the deposition of the truck driver, you probably also want this notice of deposition. Notice of Taking Deposition of Organization Regarding Control of Driver and Independent Negligence of Organization in MVA.
# 8. Photo Assignment Checklist. This is the form to give your investigator or client in every motor vehicle accident case in your office. The approximate 24 photos you need in every MVA case. Photo Assignment Checklist.
# 9. Initial Litigation Hold - Spoliation Notice - to Truck Company This copyrighted Plaintiff's Initial Spoliation Letter to Truck Company is so powerful, even experienced truck company risk management officers will know you are organized and loaded for action.
All the best,

Leonard Bucklin
P.S. to personal injury attorneys . The forms in this suite are needed by an attorney handling BI auto and truck accidents, whether on the plaintiff or defendant side of the table. Please be aware that some of the individual forms in this suite have special prices available to you until midnight,.
There are additional forms in our Bodily Injury legal forms section of the catalog, which are applicable to Motor Vehicle Accidents.
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by Leonard Bucklin,
See
Purchaser's Agreement, Our Disclaimers.
The deposition question outlines in this area of the product catalog are applicable to the depositions and witness preparation of the driver, his/her employer, investigating police officers, passengers, and witnesses in car, auto, truck, and motorcycle accidents. For other areas of litigation, see our Product Catalog. The author, editor, and publisher do not offer legal advice and intend to sell only to attorneys and those securing products for their employer attorney.