We represent car accident victims in personal injury and workers’ compensation cases across Virginia. We are aggressive in our discovery efforts. Why? Because we want to uncover every fact that can help you get the best financial result.

Taking the deposition of the adverse driver is part of conducting discovery for our clients. Below are common questions for defendant driver in auto accident cases:

Cell Phone

We ask questions about cell phone use to determine if the defendant driver was distracted when he hit you. These questions include:

Q: Did you have a cell phone in the car at the time of the accident?

Q: What is your cell phone number?

Q: Who is your cell phone service provider?

Q: Do you have a record of the calls made that day? (If not, we will ask the defendant driver to produce the record at a later date)


We want to know if the defendant driver had vision problems. To find out we ask the following questions:

Q: Do you wear glasses?

Q: Do you wear contact lenses?

Q: Have you had any visual tests in the past ten years? If so, when and where?

Q: What were the results of those tests?

Q: Do you have any visual restrictions on your license?

Q: Were you wearing your glasses or contact lenses at the time of the accident?

Q: Were you wearing sunglasses at the time of the accident?

Q: Has the Virginia Department of Motor Vehicles tested your vision and, if so, what were the results?


Q: Did you have any passengers in your car at the time of the accident?

Q: If yes, please provide the name, address and telephone number of that passenger?

Q: What is your relationship with the passenger?

Q: Who witnessed the accident? Please provide their contact information.

Damage to Vehicles

Q: Was your car damaged?

Q: Describe the damage to your car (where, how bad, etc.)

Q: Do you have photographs of the damage?

Q: Has your car been repaired?

Q: Who repaired it?

Q: How much did it cost to repair?

Q: Did you have any damage in the same area of the car from another accident? If yes, please describe.

Q: Did my client’s car have any damage?

Q: Describe the damage.

Q: Did you take pictures of the damage?

Q: Did you offer to repair the damage?


Q: Did you give an oral or written statement to the police?

Q: What did you tell the police?

Q: Did the police issue a ticket or citation to you?


Q: What were the weather conditions at the time of the accident?

Q: What were the lighting conditions at the time of the accident (day or night; sun out or not)?

Q: Did you have trouble seeing at the time of the accident?

Q: If so, what did you do to make sure you could see while driving?

Pedestrian Accident Questions

We need additional information when representing a pedestrian struck by a car:

Q: Did you hit my client with your car?

Q: What part of your car hit my client?

Q: Where did you strike my client?

Q: What happened to my client after you struck him (how far did he go through the air)?

Q: Was this the first time you have hit a pedestrian?

Q: Have you received a citation for violating a pedestrian’s right of way before this accident?

Q: Did you see my client before you struck him with your vehicle?

Q: Where did you find my client after you struck him? Describe his injuries?

These are just some of the questions we ask. If you have more questions about an auto accident claim or discovery in personal injury cases, call or email us today. Your consultation is free.