DEPOSITION PRACTICE DRILL

 

Q:   Officer Sharp, what was your occupation on June 15, 1999?
A:   I was a patrolman with the City of Huntington.

Q:   Are you still with the police department?
A:   No, sir.  I have since retired.

Q:     Back on June 15, 1999, as part of your official duties, were you called to an accident at Park Avenue and Fifth Street?
A:   Yes, sir.

Q:   Since this accident occurred several years ago, did you look at your memorandum book before you came to court?
A:  Yes.

Q:   Is it part of the regulations of the police department that a policeman should keep a notebook of these occurrences?
A:   Yes, sir.

Q:   And you have looked at your notebook with reference to this accident; is that right?
A:   Yes, sir, that’s right.

Q:   Did that refresh your recollection of what happened then?
A:   Yes, sir.

Q:   Now, do you recall, when you got to the scene of the accident, seeing the driver of one of the cars?
A:   Yes, sir.

Q:   Now, Officer Sharp, do you recall whether or not Mr. Berger was conscious when you saw him?
A:   Yes, sir, he was.

Q:   Did you talk to him?
A:   Yes, sir, I did.

Q:  Did he talk to you?
A:   Yes, sir.

Q:   Did you do something with reference to some money that this Mr. Berger had with him?
A:   Yes, sir.

Q:   Will you tell the Court and the jury what you recall doing with this money, after refreshing your recollection with your memorandum book.
A:   At the time of the accident, after he had turned his license and registration over to me, he told me he had a large sum of money and would I take it for safekeeping, which I did.  The money amounted to approximately $958 in cash.  The money was contained in three envelopes.

Q:   Did he turn this money over to you right at the scene of the accident?
A:   Yes.

Q:   Did you give him a receipt for the money?
A:   Yes.

Q:   Did you later turn the money in at your station?
A:   Well, at the time that I was turning this money in at the station, his daughter arrived at the station and was asking about the money.  At this time I was instructed to go to the hospital with the daughter and get a receipt from her and Mr. Berger for the amount of money that I was turning back to him.  I have his signature here in my book, and I have the signature of the daughter also.

Q:  Thank you, Officer Sharp.  Now, have you also examined your daily report in connection with this accident, which you had signed at the time?
A:   Yes, sir.

Q:   Does reading this report refresh your recollection as to what you saw at the scene of this accident?
A:   Yes, sir.

Q:   Will you tell his Honor and the jury what you remember about where Mr. Berger’s car was when you arrived at the scene?
A:   Yes.  I arrived at the scene at approximately 6:30 a.m. that particular morning.  I found that there had been an automobile accident at the intersection of Park Avenue and Fifth Street, which would be the westbound lane of Park Avenue.  I observed one car directly in the center of the road, and the second car had collided with a third car and had also struck a traffic light pole.

Q:   When you saw the car, was that pole knocked over?
A:   Yes.

Q:   Was Mr. Berger’s car up on the curb?
A:   Yes, sir.

Q:   Was it then in contact with the parked car?
A:   Yes, sir.

Q:   Did you see debris there which indicated to you the point of impact of the cars?
A:   Yes.

Q:   Where was that debris?
A:   It was in the center of the intersection.