I have just returned from Hawaii where I took a deposition of my client because he has a fatal lung cancer and I wanted to perpetuate something of him by way of  video deposition. Here is the basic outline I prepared, however the client has a tracheotomy and is unable to speak.  He also has a serious hearing  problem, both the result of over radiation for a head tumor. He is in bed at home and the only way to question him was to ask his wife the question who would repeat it through a hearing volume device. He would then write the answer on a pad and the wife would read it into the record. His medications made it difficult for  him to function fully. As a result of all of this I elected to only ask three questions I selected from list of concluding questions at the end of the outline. I thought this outline might be helpful to you in creating your own direct examination of your injured client.

                                    CLIENT DIRECT  DEPOSITOIN OUTLINE　

A. IDENTIFICATION

1. NAME, ADDRESS
2. MARITAL
3. HOW LONG
4. CHILDREN
5.  How many
6.  How old
7. BIRTH DATE – age
8. EDUCATION
9. WIFE’S NAME
10. WORK OUTSIDE HOME – WHAT

 B. EMPLOYMENT

1. WHAT WAS YOUR EMPLOYMENT?
2. JOB DUTIES
3. HOW LONG
4. WHEN WORKED LAST

C. ACTIVITIES AND HEALTH BEFORE INJURY

1. GENERAL HEALTH BEFORE YOU WERE INJURED
2. NORMAL ACTIVITIES BEFORE YOU WERE INJURED

D. SAW DOCTORS  

E. TREATMENT

1. DESCRIBE THE TREATMENT YOU RECEIVED
2. OVER WHAT PERIOD OF TIME

F. DESCRIPTION OF PROBLEM

1. HOW DID YOU REALIZE THERE WAS A PROBLEM

 

G. AFTER SITUATION

H. PRESENT SITUATION

1. WHAT IS YOUR PRESENT HEALTH CONDITION
2. HOW DOES YOUR CONDITION EFFECT YOU

I. PROBLEMS WITH EVERY DAY LIVING 

J. CONCLUDING QUESTIONS

(Consider one or more of the following)

1. WHAT’S THE HARDEST THING YOU DEAL WITH EACH DAY
2. WHAT DO YOU WISH FOR YOUR CHILDREN
3. IF YOU COULD CHANGE ONE THING WHAT WOULD THAT BE
4. WHAT DO YOU WISH FOR YOURSELF RIGHT NOW
5. ARE YOU SCARED – WHY?
6. HOW HAS THIS CHANGED HOW YOU SEE YOURSELF
7. HOW HAS CHANGED HOW YOU SEE YOUR WORLD

 

1. WHY DID YOU CONSULT DOCTORS

2. WHAT DID THEY DECIDE WAS YOUR HEALTH PROBLEM

3. WHAT DID THEY RECOMMEND