BRIDGE DEPO PRACTICE QUESTIONS AND ANSWERS
Use with your attorney. Not legal advice.
ADDENDUM — PRACTICE USING THE JAN 11, 2021 HOME INSPECTION REPORT
Inspector: Chris Lowe, Imperial Home Inspection (President/Master Inspector)
Key items noted: creek at rear; photo shows small bridge with netting and a bright yellow sign; inspector could not determine flooding risk; recommends city/insurance/soils-engineer research; “ask sellers for more information; talk with neighbors.”
Seller’s ownership window: Sept 27, 2019 – Feb 12, 2021.
Buyer’s inspection date: Jan 11, 2021 (pre-closing).
WHY THIS DOCUMENT MATTERS
• Shows buyers had independent, professional notice of: (a) the creek, (b) warning signage/netting, (c) need for further investigation.
• Photo corroborates that the bridge area was posted/blocked during seller’s ownership (helps on “permission,” “interruption,” and “danger” facts).
• Limits opinions: the inspector said “unknown” on flooding; seller should not speculate or adopt expert opinions.
GENERAL APPROACH WHEN ASKED ABOUT THIS REPORT
• Only confirm what you personally know: whether you saw the report, whether the photo matches what you saw, and what you did or did not do.
• Avoid legal conclusions or engineering opinions.
• Let the document speak for itself. Read before answering.
• Keep answers within your dates of ownership.
SECTION A — FOUNDATION QUESTIONS ABOUT THE REPORT
Q1. Did you commission or attend the Jan 11, 2021 inspection?
MODEL ANSWER: “No. I did not hire the inspector and I did not attend.”
YOUR FACTS/NOTES: __________________________________________________
Q2. Before closing, did you see this inspection report?
MODEL ANSWER (choose what’s true):
A) “I don’t recall seeing it before closing.”
B) “I saw it shortly before closing.”
C) “I only saw it after the sale.”
YOUR FACTS/NOTES: __________________________________________________
Q3. Looking at the photo in the report, does it match what you saw during ownership?
MODEL ANSWER: “Yes. The photo shows the small bridge area with netting and a bright yellow warning sign, consistent with how it looked during my ownership.”
YOUR FACTS/NOTES: __________________________________________________
Q4. Did you place or remove the netting or the yellow sign?
MODEL ANSWER: “I did not remove safety barriers or warning signs during my ownership.”
YOUR FACTS/NOTES: __________________________________________________
Q5. Did you rely on the inspector’s opinions about flooding or creek behavior?
MODEL ANSWER: “No. I did not form any engineering opinion. The report says the risk was ‘unknown’ and recommended that the buyers research further.”
YOUR FACTS/NOTES: __________________________________________________
SECTION B — “ASK THE SELLER FOR MORE INFORMATION”
Q6. Did the buyers (or their agent) ask you for more information after receiving this report?
MODEL ANSWER (choose what’s true):
A) “I don’t recall receiving any follow-up questions.”
B) “They asked about the creek/bridge and I referred them to the existing warning and to do their own investigation.”
C) “Please see my written disclosure documents; they speak for themselves.”
YOUR FACTS/NOTES: __________________________________________________
Q7. What information did you provide about the creek or bridge?
MODEL ANSWER: “I provided the standard seller disclosures and the title report. The bridge area was posted ‘Do Not Cross—Dangerous’ during my ownership.”
YOUR FACTS/NOTES: __________________________________________________
Q8. Did you ever tell the buyers the bridge was safe to use?
MODEL ANSWER: “No.”
YOUR FACTS/NOTES: __________________________________________________
SECTION C — NEIGHBOR ACCESS / EASEMENT ELEMENTS
Q9. During your ownership (2019–2021), did you observe neighbors openly using the bridge?
MODEL ANSWER: “I rarely observed anyone crossing there, and the area was posted and blocked.”
YOUR FACTS/NOTES: __________________________________________________
Q10. Did you grant permission to anyone to cross?
MODEL ANSWER: “No.”
YOUR FACTS/NOTES: __________________________________________________
Q11. Was the path continuously open during your ownership?
MODEL ANSWER: “No. The bridge area was blocked and posted as dangerous.”
YOUR FACTS/NOTES: __________________________________________________
SECTION D — NUISANCE / INTERFERENCE
Q12. Did anything you did make conditions worse for neighbors?
MODEL ANSWER: “No. I did not change the blocked/posted condition.”
YOUR FACTS/NOTES: __________________________________________________
Q13. Did you ever remove barriers or unlock anything that would allow crossing?
MODEL ANSWER: “No.”
YOUR FACTS/NOTES: __________________________________________________
SECTION E — FLOODING / ENGINEERING OPINIONS
Q14. Can you tell us whether the creek could cause flooding?
MODEL ANSWER: “I don’t know. I am not qualified to assess flooding. The inspector wrote ‘unknown’ and recommended further evaluation.”
YOUR FACTS/NOTES: __________________________________________________
Q15. Did you hire a soils engineer or similar expert?
MODEL ANSWER: “No.”
YOUR FACTS/NOTES: __________________________________________________
SECTION F — POST-CLOSING
Q16. After the sale, did the buyers contact you about creek, bridge, or access issues?
MODEL ANSWER: “I don’t recall post-closing complaints.”
YOUR FACTS/NOTES: __________________________________________________
Q17. Do you know what the buyers did with the bridge or path after closing?
MODEL ANSWER: “No. I did not observe the property after closing.”
YOUR FACTS/NOTES: __________________________________________________
SECTION G — “TRAP” PRACTICE USING THE REPORT
TRAP 1: “Since the report told buyers to ask you for more info, you were obligated to explain everything about the creek, correct?”
SAFE MODEL: “I provided the standard seller disclosures and the title materials. The document speaks for itself. I answered questions I received to the best of my knowledge.”
YOUR FACTS/NOTES: __________________________________________________
TRAP 2: “This photo proves you knew the bridge was safe if people were careful, right?”
SAFE MODEL: “No. The area was posted ‘Do Not Cross—Dangerous’ and netted off. I can’t say it was safe.”
YOUR FACTS/NOTES: __________________________________________________
TRAP 3: “The inspector said to talk to neighbors; that means you knew neighbors were using the bridge, correct?”
SAFE MODEL: “The report speaks for itself. During my ownership, I rarely observed anyone crossing, and the area was posted and blocked.”
YOUR FACTS/NOTES: __________________________________________________
TRAP 4: “Isn’t it true you hid flooding problems from the buyers?”
SAFE MODEL: “No. I provided the required disclosures. I did not have expert knowledge about flooding, and the buyers independent inspector recommended the buyers do further investigation.”
YOUR FACTS/NOTES: __________________________________________________
TRAP 5: “So you admit there was a dangerous condition you failed to fix.”
SAFE MODEL: “The area was posted as dangerous and blocked during my ownership. I did not remove warnings or barriers.”
YOUR FACTS/NOTES: __________________________________________________
SECTION H — DOCUMENT-HANDLING PHRASES (WHEN SHOWN THE REPORT)
• “I recognize this as the buyers’ inspection report. I did not commission it.”
• “This photo appears consistent with how the bridge area looked during my ownership.”
• “The document speaks for itself; I can read what it says.”
• “I’m not offering an engineering or legal opinion.”
YOUR FACTS/NOTES: __________________________________________________
SECTION I — TIMELINE BOX (WRITE THESE IN YOUR OWN WORDS)
• My ownership dates: _______________________________________________
• What I personally saw at the bridge (short bullets): _________________
• What I did NOT see / do NOT know: __________________________________
• If buyers asked me questions after the report: _______________________
• Where my photos/texts/emails are stored: ____________________________
Signature (practice sheet addendum complete): __________________ Date: ______
TWO-MINUTE REMINDERS (READ BEFORE THE DEPOSITION)
1. Tell the truth; answer only the question asked.
2. Time-box: “During my ownership (Oct 14, 2019–Feb 12, 2021)…”
3. Don’t estimate or guess. “I don’t know/recall” is acceptable if true.
4. Documents speak for themselves; avoid adopting expert opinions.
5. Ask for breaks as needed; ask to rephrase nor repeat confusing questions.
6. Wait for your attorney on settlement/mediation questions.