Have to depose a veterinarian...what do I ask?

[TMomof3]

Tennessee...

short crash course...February, a neighbor's doberman was let loose willingly by owner without leash. Their dog attacked my dog (leashed) on my property and my dog suffered a lame leg..she required $2500 in surgery and now over $500 in court costs. We lost in General Sessions because the judge would not allow my vet bills as evidence (although the pro se legal help at the courthouse said I had an open/shut case..) 4 months later and an appeal to the Circuit Court...I am going to depose the veterinarian on July 19th rather than subpoena him and have him deal with all the continuances I'm sure my neighbor's attorney will try and work. (They agreed to pay for the surgery then the next week they were divorced, sold their house, and told me to sue them...he was cited by our County for failure to restrain pet and pled guilty)

My question now is what do I ask him? Is there a website or any books that might walk me through how to administer a deposition? I've arranged for a court reporter to be there and the defendant's counsel is aware of the date...anything you can help so I look like I've got my act together in front of their attorney and protect my case by making sure I've asked the right questions? Their attorney has threatened to make me pay $4,000 in their attorney fees for bringing a frivolous case...I've been informed that's not right...but I'm dealing with a rich kid who thinks he can run over people.

Thanks!
Tara

[You Are Guilty]

You can start by reading this to get some ideas: [url]http://www.attorneys-med-serv.com/atla_dup.html[/url]

It's not entirely applicable to your situation but it should at least get you pointed in the right direction. Don't forget to also include the bills, and the necessity of each item charged for.