This Personal Injury Deposition Commonly Asked Questions document sets forth many
of the essential questions that must be posed to a medical doctor in a personal injury
case. This list provides an attorney with a solid foundation from which to conduct the
deposition. Furthermore, this document ensures that crucial questions are not
overlooked. An attorney should review this list before deposing a medical doctor in a
personal injury case and customize it accordingly to fit the situation. This document
should be used by attorneys conducting depositions or doctors before being deposed to
know what to expect.
Personal Injury Medical Doctor Deposition Commonly Asked Questions
1. Please state your full name for the record.
2. Are you known by any other names?
3. This deposition is being provided pursuant to a subpoena served upon you, is that
4. And you are aware that you have a right to counsel here?
5. Did you meet or spoke with an attorney before this deposition?
A. If so, who was the attorney?
B. How long was your meeting?
C. How many meetings did you have?
6. Are you represented by an attorney today?
7. Have you ever had your deposition taken before?
8. Do you understand that you’ve been sworn in by the court reporter and that you’re
obliged to tell the truth?
9. You will have a chance to review this testimony in booklet form, make any changes that
you deem necessary, and that any changes you make that are material in nature can be
commented on at a hearing or trial, so it’s important you give your best testimony. Do
10. I’m entitled to estimates, approximations and not guesses. I’m also entitled to answers
for which you have a factual basis for providing that answer, understand? You
understand the difference between a guess and an estimate or approximation?
11. If you don’t understand a question, please tell me, otherwise we’re going to assume you
understand the question, ok?
12. Please answer in audible responses; no nods.
13. If applicable ONLY (have counsel present), you can meet with counsel if you wish.
14. Did you review any documents before this deposition?
15. If YES, have those documents been produced pursuant to our last subpoena on
________________ [Instructions: Insert date, if applicable]?
A. Are there any other documents that need to be produced that haven’t been?
16. Doctor, do you have a copy of your resume / curriculum with you?
[Comment: If applicable, attach resume / CV and mark it as an exhibit]
17. Where did you go to medical school?
18. Where did you complete your residency?
19. You currently practice at ____________ [Instructions: Insert practice location],
A. How long have you been at ____________ [Instructions: Insert practice
B. What is your specialty at ____________ [Instructions: Insert practice
C. When are you in at ____________ [Instructions: Insert practice location]?
D. What is your title at ____________ [Instructions: Insert practice location]?
E. What is it you do? Who are you in charge of in a supervisory capacity?
20. Are there any other places you currently practice at?
A. IF YES, what’s the name of the other place?
B. What’s the address of the other place?
C. Is there a phone number of the other place?
D. How long have you been there?
E. What is your specialty there?
F. What sort of patients do you see there?
G. When are you there?
[Comment: The following questions are relevant if the doctor is being designated as a
witness in the case.]
21. Have you ever testified as a witness before?
22. Have you ever testified as an expert before?
23. Have you qualified as an expert at trial? At a deposition?
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24. Do you know if you’ve been designated as an expert by ____________ [Instructions:
Insert name of relevant party] in the subject case ____________ [Instructions: Insert
name of case]?
25. Have fees been tendered by ____________ [Instructions: Insert name of party]
retaining you as an expert in this case?
26. There are no writings between you and ____________ [Instructions: Insert name of
relevant party] regarding you acting as an Expert on her behalf in this case, correct?