"May I draw your attention to __(date)___, was there an incident?"
"And what did this incident entail?"
"How many vehicles were involved?"
"Were you one of the drivers?" etc.
Gawd, it's like riding a bike. It all comes back.
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i'm terrible with quotes on the replies -sorry.
anyway, now you got me started - so stand back!
you are going the high route - the depositions usually go more like this:
(after the reporter gets the name and address, and even before that, everyone agrees to standard stips (which are different from each reporting company!) :
preamble, i.e. i'm going to be nice before i shtuff you in the tuchas real hard.
then i (and many other lawyers) like to ask if they were involved in an accident, and when they say yes, what date. As if them not knowing the date lessens the case. I get all warm and fuzzy when instead they ask my client, "Were you involved in an accident on <insert date>"
The, "What did the incident entail" part - objection - calls for a narrative response - although if i'm tired, hungry or bored, or i think the client can answer alright then i'll allow it, otherwise i make the adversary work for their money...when you're using an interpreter, though, you do anything you can to finish up....
how many vehicles - yup, valid question. never the word crash, but rather "impact" or "did your vehicle come into contact with another vehicle?" at which point you either get a yes, or a "huh?" and you have to rephrase
I NEVER use prior or subsequent - amazing how many liars do! simple is the key - before or after...
my favorite objections: 1) hearsay - you NEVER hear anyone object to these during the deposition (because a lot of the time you have hacks). and we can have a nice long post about hearsay
favorite objection 2) "So, is it fair to say..." at which point I object before even getting to the next part - I hate those, and I won't allow a shyster, err, fellow barrister to put words into my client's mouth when they do the ol' "fair to say" and summarize the last few responses, and for that matter, who says what is fair? that's a jury question (i think) so i just don't allow the fair to say schpiel.
Products liab - I've done the groundwork on those - VERY COMPLICATED, VERY EXPENSIVE to prosecute - now if i get a products case (very rare) I call Anthony Gair - have you worked opposite him? Top notch fellow.
Geez, I hate practicing law. But it's better than screwing up my phpbb board