If the driver admits they did something wrong then there’s no need to take the deposition. But there’s a reason that there are so many lawyers. Exhibit A - big bad insurance companies. Here are some of the pitiful excuses they make in straight forward rear end cases:
- the sun was in her eyes
- it had been raining
- the medication made him sleepy
- the car in front stopped too quickly
- foot slipped off the brake pedal
- was looking at the speedometer
- it was dark out
The list goes on and on.
Here is a very basic outline that can be used as a starting place to depose a defendant driver. If you are really prepared – you can insert what you already know in the “other info” column. It rattles the defendant when you ask leading questions confident already of the answers.