DIRECT EXAMINATION OUTLINE FOR YOUR OWN CLIENT
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…