Mr.

Scott my name is Alina Morros, and I represent the Plaintiff, Joel Ortiz in this case, and before we get started, I just want to make sure that you understand the deposition process. Okay? Do you understand that the testimony that youre giving today is under oath? Do you understand that the testimony you are giving today has the same force and effect just as if you were testifying in front of a judge or jury? At any time during your deposition, if I ask you a question that you do not understand, I want you to let me know, okay? At any time during your deposition, if I ask you a question that you do not remember, feel free to say that you do not remember. Im going to be asking you questions about time, speed, distance and that sort of thing, and again, I dont want you to guess at anything, but I may try and help you give me whats called your best estimate. All right. The court reporter is taking down everything thats being said at the table, and she cant take us both down at the same time, so just be mindful of that and wait until Im finished asking my questions before you begin to answer the question. Okay? And also, in the same vein, she cant take down nods of the head yes, no, or shoulder shrugs, so you actually have to articulate yes or no or I dont know or whatever it is youve trying to say. Ok, what is you full name? What is your current address? Is this the same address listed on your drivers license? How long have you lived at this address? Is this the same address where you were living at the time of the accident on ____? What is your date of birth? Id like to go off the record for a moment: What is your social security number? Id like to go back on the record Are you married? What is your spouses name?

Tell me a little bit about your educational background o Dentist

And what is your occupation? Where do you currently work? How long have you worked there? Where did you work before this job? Did you bring your drivers license with you today? o I would like to request that a copy of Mr. Scotts drivers license be introduced as Exhibit A

Have you had any formal drivers education? Has your license ever been suspended? Have you ever been convicted of a criminal offense? Have you ever been charged with a criminal offense that would carry a punishment that exceeds one year in prison? o o o What was the offense? What was the date of the offense? In your Answers to interrogatories I noticed that you said that you have not been convicted of a crime, is that because you were sentenced to probation? Has that matter been resolved? Would you like to amend your answer to interrogatories at this time?

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Do you wear prescription eye glasses? o Any restrictions past or present on your license? Drive with them, near sighted

Have you had any prior accidents? o o If so, when? Who was at fault? Any lawsuits resulting from prior accidents?

Who owns the vehicle that was involved in the accident?

How did you get the keys?

How often did you drive or do you drive the vehicle per week? Who is responsible for the maintenance of the vehicle? o Do you remember the number of miles on the vehicle at the time of the accident? Were the brakes checked? Were the tires changed? Were there any mechanical defects with the vehicle at the time of the collision?

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Have you ever given a deposition in an auto accident? Have you visited the scene of the accident since the date of the accident? o If so, were there any changes at the scene of the accident?

Aside from any conversations you may have had with your attorney, have you prepared for this deposition in any way? o Reviewed documents or photos? Police report? Written statement to insurance company?

Where were you coming from and where were you going before the accident occurred? o o o Do you remember the time that you left? Do you remember how long it should have taken you to arrive? What route did you take?

Describe the accident o Date, time, and place of accident Were there any Median or yellow lines dividing the road? What lane were you traveling in? Was there a traffic signal? What color was the signal

Were there any obstructions to your view? Sun? Other Vehicle?

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You testified that you looked left, approximately how long did you look? Did you see any vehicles approaching? Cell phone? Where was it located? What is your cell phone number?

Who is your cell phone carrier?

What did you do immediately after the collision? o o o o o o o Were there any skid marks on the floor? Was the vehicle in front of you moving or stopped? Were the brake lights of the vehicle on? Why was the vehicle stopped? Was there a turn signal on? Was there a vehicle in front of that vehicle? Do you know if the vehicle in front of you see your vehicle in the rear view mirror? Distance between rear vehicle and vehicle in front? When did you first notice the vehicle in front of you?

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What were the weather conditions like? o Was it raining? How long, if not, when did it stop? Was roadway wet? Did you notice the wet road before the accident

How fast were you traveling about a quarter of a mile before the collision?

Please describe what you did after the collision occurred o o What did the driver of the vehicle that you rear ended do? Did you speak to anyone at the scene of the accident? o What was the discussion? Were there any injuries?

What did the individuals in the other vehicle look like? Were they injured? Shock? Intoxicated? Fatigued?

Did the police come to the scene of the accident? o o Who notified the police? Did you speak with the officer? o o What did he or she say?

Any witnesses to the accident? Was there a police report

Was there any damage to your vehicle? o Did you have it repaired? o o What was the cost of the repair

Did you take any photos of your vehicle? What was the condition of your vehicle prior to the accident?

Were there any citations issued as a result of the accident? o Were you cited for the collision? If so, was there a fine paid? Plea entered?

Did you have any alcoholic beverages 12 hours prior to the collision?

Did you take any medications 12 hours prior to the collision?