Deposing Truck Drivers and Trucking Company Representatives in Injury Cases

Questioning Deponents, Using Demonstrative Exhibits, Raising and Defending Objections, Dealing With Difficult Deponents, and More

Recording of a 90-minute CLE webinar with Q&A

Conducted on Wednesday, May 24, 2017
Recorded event now available

This CLE webinar will prepare personal injury attorneys representing victims in trucking injury cases to depose truck drivers and trucking company representatives. The webinar will discuss best practices for effectively questioning deponents, videotaping driver depositions, using demonstrative exhibits, dealing with difficult drivers or trucking company representatives, and raising and defending objections. The panel will also discuss how to skillfully navigate Rule 30(b)(6) of the Federal Rules of Civil Procedure when preparing deposition notices for trucking company corporate representatives.


For personal injury attorneys representing victims in trucking accident cases, the depositions of the truck driver and trucking company representatives can be the most significant events in the case. Effective questioning of truck drivers can reveal a driver’s medical state, whether he or she was fatigued, and whether the driver was familiar with and complied with federal safety standards and trucking company policies and procedures on safety.

Depositions of trucking company representatives allow personal injury attorneys an opportunity to scrutinize the trucking company’s policies and practices to determine if safety is a true priority. Testimony obtained from the trucking company representative during the deposition binds the trucking company.

There are several strategic moves personal injury counsel should consider when deposing truck drivers and trucking company representatives, including videotaping the depositions and using demonstrative exhibits such as the Federal Motor Carrier Safety Regulations and driver logs. When preparing to depose trucking company representatives, personal injury attorneys must be sure to get the scope of the deposition notice in accordance with Rule 30(b)(6) of the Federal Rules of Civil Procedure.

Listen as our experienced panel explains legal and practical considerations for personal injury attorneys when preparing for and conducting depositions of truck drivers and trucking company representatives in trucking injury cases. The panelists will share useful insights on the strategic and effective use of these depositions.


  1. Preparing for the deposition
    1. Notice requirements for 30(b)(6) deposition of trucking company representatives
  2. Conducting the deposition
    1. Questioning the driver and corporate representative
    2. Videotaping the deposition
    3. Using demonstrative exhibits
    4. Raising and defending objections
    5. Dealing with evasive or difficult deponents


The panel will review these and other key issues:

  • What topics should personal injury attorneys explore when questioning truck drivers and trucking company representatives during depositions?
  • When and how should personal injury attorneys use demonstrative exhibits during depositions of truck drivers and trucking company representatives?
  • What are some best practices for crafting a deposition notice for the trucking company representative that sufficiently defines the scope of the 30(b)(6) deposition?
  • What are some best practices for dealing with difficult deponents?
  • What are some effective techniques for raising and defending objections during depositions of truck drivers and trucking company representatives?


Timothy M. Whiting, Founding & Managing Partner
Whiting Law Group, Chicago

Mr. Whiting is a leading truck accident and personal injury attorney, focusing on holding trucking companies, truck drivers and others in the transportation chain accountable for injuries to victims of personal injury and trucking accidents across the country. His track record reflects winning jury verdicts and settlements in over 10 counties across four states, winning more than $130 million in awards for clients.

J.J. Burns, Esq.
Dollar Burns & Becker, Kansas City, Mo.

Mr. Burns focuses on truck crash litigation, and handles a range of other catastrophic injury cases. He has researched and written extensively about many of the details that impact truck crash litigation and other catastrophic injury cases. Mr. Burns has paid particular attention to one such detail that can prove detrimental to plaintiffs—an anachronistic legal rule operating in nearly half the country that allows a motor carrier to conceal its own negligence in hiring, training or supervising its driver by simply admitting that the negligent truck driver was its employee at the time of the crash. He is the national authority on the issue.

Steven M. Gursten, Atty
Michigan Auto Law, Farmington Hills, Mich.

Mr. Gursten focuses his practice on serious auto and truck accident injury and wrongful death cases. He frequently lectures at legal seminars throughout the country on trial advocacy, trucking litigation, and traumatic brain injury cases. He has recovered the top-reported jury verdict for a car or truck accident in Michigan for multiple years, according to published reports. He serves as President of the Motor Vehicle Trial Lawyers Association and a Past Chair of the American Association (AAJ) for Justice Truck Accident Litigation Group. 


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Baroumes & Bruen

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