Checklist for Direct Examination of Employer or Co worker | Florida accident Law

A. Background information.
1. Please introduce yourself to the jury.
2. What is your residence and occupation?
3. What is your relationship to the plaintiff?
4. How long have you known the plaintiff?
5. Did you have the opportunity to observe the plaintiff before (date of incident)?

B. Plaintiff's work background.
1. What kind of worker was the plaintiff before (date of incident)?
2. What kind of attitude did the plaintiff have about his work?
3. Did you ever hear any complaints about the plaintiff's job performance?
4. What was the plaintiff's record of attendance prior to (date of incident)?
5. (If employer) What was the plaintiff's rate of pay prior to (date of incident)?

C. Plaintiff work history after incident.
1. What changes, if any, have you noted since the date of __________?
2. When did the plaintiff return to work?
3. (If employer, introduce exhibits such as attendance record, and pay schedule confirming loss of income.
4. Has the plaintiff complained of any physical problems since (date of incident)?
5. Have you had the opportunity to observe the plaintiff since his return to work? If so, describe any changes.
6. Have you had to make any adjustments as a coworker or employer since the plaintiff's return to work? If so, what adjustments have you had to make?