1. Mrs. Jones, how far away were you from the intersection when you first noticed the other car?
  2. At the time you first noticed the other car, what was your speed?
  3. Where had you been coming from?
  4. Where were you going to?
  5. What time did you plan on getting there?
  6. Were you meeting anyone at a specific time?
  7. What were the weather conditions like minutes before the accident?
  8. When you first noticed the other car, was roadway that you are on straight or curved?
  9. When you first noticed the other car were you going uphill, was a roadway flat, or was downhill?
  10. When you saw the other car for the first time ,were you speeding up, coasting, slowing down or maintaining the same speed?
  11. When you saw the other car for the first time, where was it?
  12. In the time you saw the other car, how long did it take you to travel that distance until you reached the intersection?
  13. Did you apply your brakes at any time between first noticing the car and the time you reached the intersection?
  14. Were your brakes working?
  15. Was your horn working?
  16. Did you sound your horn at any time from when you first noticed the other car and the time you got to the intersection?
  17. Was your car radio on or off?
  18. Were your windows open or closed?
  19. Did you have a cell phone or smartphone in your hand?
  20. Were you texting?
  21. Were you on the telephone speaking to anyone?
  22. Do you wear eyeglasses?
  23. Do you have any difficulty hearing?
  24. Are you colorblind?
  25. Do you have any restrictions on your New York State driver's license?
  26. For the time you noticed the other driver's car, until you reached the intersection, what was the color of the light?
  27. When was the time you first saw the other driver before you reached the intersection?
  28. Were there any cars directly in front of you as you are approaching the intersection?
  29. Were there any cars directly behind you or to the side of you as you were approaching the intersection?
  30. In the time you noticed the other driver, until you arrived at the intersection, were there any cars from any other direction turn in front of you and across you?
  31. What part of your car came into contact with what part of the other car?
  32. Was the other driver moving or stopped at the time of impact?
  33. In what direction was the other driver traveling when the two of your cars made contact?
  34.  For how long the delight remain that color before changing?
Gerry Oginski
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NY Medical Malpractice & Personal Injury Trial Lawyer