Deposition Prep Packet (General)

Deposition Prep Packet (General)

Depositions are one of the most powerful tools in healthcare litigation. This packet provides structured question sets designed to uncover deviations from standards of care, expose communication failures, clarify staff responsibilities, and reveal systemic issues that contributed to patient harm.

Use this packet to prepare for depositions of nurses, physicians, therapists, aides, administrators, and corporate representatives in any healthcare negligence matter.

Nurse Deposition Questions (Any Setting)

Role & Responsibilities

• Describe your responsibilities for this patient.
• What was your caseload during the relevant period?
• What training have you received related to assessments, monitoring, and escalation?

Interventions

• What interventions were performed in response to symptoms?
• Were interventions timely?
• Was the patient reassessed afterward?

Assessment & Monitoring

• What assessments were performed at admission?
• How often were vitals required?
• Were any assessments missed or delayed?
• Did you notice any changes in condition before the escalation event?

Communication

• When did you notify the provider of changes in condition?
• What information did you communicate?
• Were there any delays in communication?

Documentation

• Did you document assessments and interventions in real time?
• Are there any gaps or late entries?
• Is there documentation of family/caregiver communication?

Physician / Provider Deposition Questions

Role & Oversight

• What was your involvement in the patient’s care?
• How often did you review nursing documentation?
• How were abnormal labs or vitals communicated to you?

Orders & Follow-Up

• What orders were given in response to symptoms?
• Were follow-up assessments expected?
• Were you notified of deterioration in a timely manner?

Standards of Care

• What would a reasonably prudent provider have done in this situation?
• Were any red-flag symptoms present?
• Should escalation or transfer have occurred sooner?

Administrator / DON / Supervisor Deposition Questions

Policies & Procedures

• What policies applied to this patient’s care?
• Were those policies followed?
• How is staff trained on standards of care?

Staffing & Oversight

• What were staffing levels during the relevant period?
• Were there any missed or shortened visits?
• How are missed assessments escalated internally?

Incident Review

• Was an internal investigation conducted?
• Were any corrective actions implemented?
• Were there prior similar incidents?

Corporate Representative Deposition Questions

Systems & Oversight

• How does the organization ensure compliance with standards of care?
• What quality assurance processes were in place?
• How are adverse events tracked and reviewed?

Staffing & Resources

• Were staffing levels adequate?
• Were there known shortages?
• How were staff supported during high-acuity periods?

Risk Management

• Were there prior complaints or incidents involving similar issues?
• What corrective actions were taken?

Themes to Establish Breach

• Missed or delayed assessments
• Abnormal vitals not addressed
• Medication errors
• Poor communication with providers
• Failure to escalate
• Documentation gaps or contradictions
• Unsafe environment not addressed
• No reassessment after interventions
• Delayed response to deterioration

Deposition Preparation Requires Precise Record Mastery and Strategic Issue Framing

Effective depositions depend on command of the medical record, clarity around regulatory and standard-of-care issues, and anticipation of opposing counsel’s lines of questioning. Our clinical-legal team identifies high-risk testimony areas, documentation vulnerabilities, and evidentiary leverage points to support confident, consistent, and defensible deposition performance.