Today I reviewed interrogatory responses from a Plaintiff in one of our commercial truck/vehicle collision cases. The interrogatory asked for a list of witnesses to the incident.
Plaintiff's response looked something like this:
Witnesses to the collision:
1. John Smith, pedestrian at the scene
2. John Doe, driver of the vehicle directly behind me
3. Scruffy, my dog was sitting in the passenger seat.
Wouldn't it be awesome if we could note a deposition for Scruffy? Maybe we'd have to hire a dog whisperer as a translator. Wouldn't it be even more awesome if Scruffy spoke english and answered our deposition questions?