Monday, March 3, 2008

This attorney earned his money

Q. How about after April 1, 2006, but unrelated to this
accident, were you ever seen in an emergency room of a hospital?
A. Don't remember.
Q. Have you ever been diagnosed with having any type of short-term or long-term
memory problems?
A. No.


Q. After April 1, 2006, that's the date of the accident for which we're here today, have
you ever left the State of New Jersey for any reason?
A. After that, yes. I went to Florida for vacation.
Q. When did you go to Florida?
A. It was before the accident.
Q. How about after the accident? I'm talking about after the accident.
A. No.
Q. You haven't left the state of New Jersey for any reason after
this accident?
A. I went to North Carolina two months ago.
Q. That was after the accident?
A. Yes.
Q. And North Carolina was not in the state of New Jersey, right?
A. Yes.
Q. Did you drive to North Carolina?
A. Yes.
Q. Did you drive with yourself or with somebody else?
A. By myself.
Q. Where was your daughter during that time?
A. With me.
Q. She went with you?
A. Yes.
Q. So you drove the car, and your daughter was a passenger?
A. Yes.
Q. Do you recall the accident that happened on April 1, 2006?
(Pause)
Do you recall that accident that you were in on April 1, 2006? Do you remember
the accident?
A. Yes.
Q. Help me here; come on.
Was the driver on a cell phone at all?
A. Your client?
Q. No, your client.
A. No.
Q. I mean your friend.
A. We were talking.


Q. Any complaints, anything bother you today?
A. It's below my bra. It's a pain, and it goes to my
shoulders, to my neck and my head. I feel like my head is heavy.
Q. You have a heavy head?
A. I think so. Yes.
Q. Anything to do with those earrings?
A. No.

Submitted by: Lisa Urso, scopist