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

An encore presentation featuring live Q&A

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

Conducted on Wednesday, October 28, 2020

Recorded event now available

or call 1-800-926-7926
Program Materials

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 are among 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 real priority. Testimony obtained from the trucking company representative during the deposition binds the trucking company.

There are several strategic moves for personal injury counsel 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 define the scope of the deposition notice correctly under Rule 30(b)(6) of the Federal Rules of Civil Procedure.

Listen as our expert 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 high priority 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 proven techniques for raising and defending objections during depositions of truck drivers and trucking company representatives?

This is an encore presentation with live Q&A.


Burns, J.J.
J.J. Burns, Esq.

Dollar, Burns, Becker & Hershewe

Mr. Burns focuses on truck crash litigation, and handles a range of other catastrophic injury cases. He has researched...  |  Read More

Gursten, Steven
Steven M. Gursten

Michigan Auto Law

Mr. Gursten focuses his practice on serious auto and truck accident injury and wrongful death cases. He frequently...  |  Read More

Whiting, Timothy
Timothy M. Whiting

Founding & Managing Partner
Whiting Law Group

Mr. Whiting is a leading truck accident and personal injury attorney, focusing on holding trucking companies, truck...  |  Read More

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