Tom Trucker is a long haul truck driver. He was driving his 18-wheeler westbound on I-10 on January 1, 2015. He was hauling a tanker trailer fully loaded with a volatile chemical, and driving 15 miles over the speed limit. As he traveled down I-10, he began to feel sick and started seeing double.
As he started feeling sick, Carrie Cutoff swerved into Tom’s lane of travel. She was using her cell phone at the time.
Tom tried to swerve away from Carrie, but overcompensated because of his distorted vision. His trailer jack-knifed and he slid into a compact car driven by Izzy Innocent.
Izzy was on her way home from church, and had just had a fusion in her lumbar spine the week before.
Izzy has sued both Carrie and Tom alleging that because of their combined negligence she suffered injuries to her lower back and neck.
Your supervising attorney represents Izzy in her claim against Tom and Carrie.
Prepare an outline of deposition questions you would recommend your supervising attorney ask Tom and Carrie.
Remember, the above are the only facts you know right now.
You will have to inquire as to the witnesses’ full names, medical conditions, what happened at the time of the accident and their version of the facts. Remember, discovery is wide open in this matter, and you can ask them anything you believe relevant to the accident or that will help to establish liability against either or both of them.
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