Deposition Prep Packet (General)
Targeted, clinically grounded deposition questions for nurses, physicians, administrators, and corporate representatives across all healthcare settings.
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 case.
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?
AIDE / CNA / TECH DEPOSITION QUESTIONS
Role & Responsibilities
• What care did you provide (ADLs, safety checks, observations)?
• How often were you scheduled to see the patient?
Observations
• Did you notice any signs of pain, distress, or decline?
• Did you report these observations to nursing?
Documentation
• Did you document your tasks and observations?
• Are there any gaps?
THERAPIST (PT/OT/ST) DEPOSITION QUESTIONS
Role & Involvement
• What was your involvement with this patient?
• How often were you scheduled to visit?
Safety & Function
• What functional assessments were performed?
• Did you identify any safety risks?
• Were recommendations communicated to nursing or the provider?
Documentation
• Are there notes documenting progress or decline?
• Were any concerns escalated?
ADMINISTRATOR / DON / SUPERVISOR 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 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
Use these question sets to uncover:
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
These themes help build a clear breach narrative.