By this point, you have established the importance of medical records as a critical part of a true and accurate history. between counsel for the plaintiff and the doctor before the first question is asked under oath. %PDF-1.4 i. Good afternoon, Dr. Doe. A statement of all amounts of money received by the doctor or his or her medical organization from attorney Wiley Fox, or his firm Fox Huntum and Brag, during the last two years. J{Hc8Dh 8o4 F\I)2hI2eiH\QiH+?l)mD$kSIl?$Qp Learn how your comment data is processed. These can range from emergency room physicians, primary care doctors, chiropractors, surgeons, pain doctors and physical therapists. Testified in any deposition or at trial before? Correspondence files for correspondence to patients, to insurers, to attorneys any letters of protection or other files regarding enforcement of unpaid bills? 15 0 obj If a physician thinks a certain medication caused an adverse outcome for a patient, then they would certainly chart it so that future treaters would have the benefit of that knowledge and steer the patient away from such therapies in the future. Rule 32 of the Federal Rules of Civil Procedure governs the use of a deposition at trial. If someone has a broken bone, you can see that on an x-ray and it is called an finding, isnt it? Q. It is not uncommon for a treating physician giving a deposition to have little or no independent recollection of the plaintiff or of their treatment of the plaintiff. stream If they are numerous, authenticate and mark each individual medical record that identifies a history of infarctions, diabetes, smoking, noncompliance, etc. Tell us about your medical background, starting with medical school. 5 (May 2004). See Appendix C. How the questions are phrased, in what order the questions are given, and what topics are covered is going to vary for each case. 10 0 obj 0000007401 00000 n Lab work or other tests that were done and what were the results. 5 0 obj Do you consider those to be reliable authorities for you to consult? Sec. A treating physician should also never give an opinion regarding another physicians medical care while being deposed. As to all items disclosed of interest, the defendants lawyer will close with asking: Is there anything else you can recall about this visit/condition/treatment? Did you know that in fact that John Jones had ___________? <> [ 11 0 R] 0000001672 00000 n xref Likewise, they did not show the doctor any of the corporate testimony involving drafters of the documents, emails or memos that may have shed some light on what was said, when it was said and why it was said. Put your fears to rest by familiarizing yourself with the procedure and preparing for predictable questions and variable responsesdue diligence before your deposition will lead to a strong defense. That is what the trial is for. 22 lowballing techniques used by unscrupulous insurance adjusters. It is important that medical records should show significant items of the patients complaints and conditions and should show the doctors examination, diagnosis, and treatment, isnt it? To embed, copy and paste the code into your website or blog: Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra: [HOT] Read Latest COVID-19 Guidance, All Aspects [SCHEDULE] Upcoming COVID-19 Webinars & Online Programs, [GUIDANCE] COVID-19 and Force Majeure Considerations, [GUIDANCE] COVID-19 and Employer Liability Issues. endstream endobj 695 0 obj <>stream Did plaintiffs counsel show you several documents prior to this deposition? 0000004096 00000 n Treating doctors carry more credibility with a jury than a retained expert. You had the benefit of the plaintiffs medical record and past illnesses, ailments and comorbidities? As good personal injury lawyers, we have all spent a great deal of time learning medicine, particularly the medicine involving orthopedic injuries. These future recommendations are reasonably certain to occur to a reasonable degree of medical certainty? The retained expert can come across as a hired gun. What type of medicine do you practice. Deposing a plaintiffs treaters should be on a case by case basis. Did you personally review x-rays or tests that you relied on? %%EOF endstream Surgeons are expensive to depose, but they are probably the star causation witness for a plaintiff. Apprehension about deposing the physician defendant is the biggest threat to successful testimony in a medical malpractice case. [1] Physicians who testify as fact witnesses in legal claims involving a patient they have treated must hold the patient's medical interest's paramount by: (e) Delivering honest testimony. When was the paper printout made from the electronic file? 1. And then mark them as separate exhibits. The long deposition submerges any flashes of good testimony for the plaintiff in a mass of detail. This field is for validation purposes and should be left unchanged. endobj They allow one side to find out what a witness or party knows about the case; It fixes a witness's story so that he/she cannot amend his/her story at trial; Under certain circumstances, it preserves the testimony for witnesses who may not be available to testify at trial; and. If you learn during the early questions that a doctor has reviewed certain documents, you must assume they have seen the worst of the worst. x\on?},\shzmQ-D}gf$ Xfo7|ysvw"rqZrqG}{f6K.]%Y*9*Reer~\$-t]i~8?2/grE2ty%3r.BGa&y*I.>%o64$YN\LL~;\SZxcDy=:TRLe2e+AWyVb8 3*L3V3JcM_QCd` TNI:eZME*&5jipbXMI(=Y6{mO_uX-d5-dNZpilAmS&_?q k:V&]Gdc";{I-Y oMdf(N4$!/yk;'/]%r$zndicvMDJ0Ll,Xv)Tdag$z=}vZ|(vh[=9aD9;FT2)4TLex(:+P0h 6i4S{HTGtL(*+,yGPjr@[]c:hQEn6iZN>cz ?$AK While there is no substitute for being prepared, you can take an effective deposition "on the fly" by remembering five essential questions and their logical subquestions: 1. Who engaged you in this case. If a mouse runs by, get its name and put it on the record. Now you have a logical segue to the medical records. A. <<8C151ED5F53D3C45872ADFD1BAFF7038>]/Prev 350918>> Names of attorneys? Oral or written report? Who asked you to this talk between yourself and Mr. Fox? xn6wTt"``iQHS7qwv#L,~!NT'O6Z}/BN?axz\.+T\ *tPAGjo?R=n8Z.~mT^..?,vKDc x S: " And if a patient brought in one single page of a medical record out of thousands, would you want to see or have knowledge of the situation to put it into context? Generally the defense gains an advantage in the deposition of a plaintiff's treating doctor by making the examination, long, detailed, and boring. 0000064012 00000 n Did they ask you to appear at a future trial of this case? Did you try to separate out how much of John Jones condition is due to his prior injury/history and how much is due to the accident he is suing about? 12 0 obj Why? If the case value warrants treater depositions, then the next step is to review those treaters records to ascertain if any favorable testimony is anticipated. document.getElementById( "ak_js_1" ).setAttribute( "value", ( new Date() ).getTime() ); This site uses Akismet to reduce spam. It does not matter that the doctor has not seen the documents, that the documents have little or nothing to do with the science of medicine surrounding the product, or that the documents are in no way temporally related to the care and treatment of the patient. Saves you time in preparing your deposition outline. What insurance adjusters look for in evaluating claims. Be confident. As a physician, there are three common reasons why you will be compelled to testify and your deposition will be taken, each of which presents its own problems and pitfalls. If you want to emphasize something favorable to your side of the case that was recorded in the medical records for a particular office visit or hospital stay, or you want to emphasize that something was not recorded (hence you can infer it did not exist) ask the following: Is this document, dated _________________, the record of _________ of John Jones? Which cases are selected for surveillance. Significant entries:(1) surgery(2) pain medication(3) therapy, 1. So, at trial you get to (a) designate and play your treating physician conclusions (not opinions!) Games insurers play in wrongfully denying claims. Have you ever been contacted by an attorney who represents the plaintiff in [current] litigation? You want to put what they are telling you in terms of their presentation into context? Zach Matthews Federal Rule 26 (a) (2) is familiar to many litigators as the rule governing expert witness disclosures. You have testified in the past as an expert on other cases on reasonable cost of medical treatment? C. Cannot depose Independent Medical Examination Doctor or treating doctors, in the absence of special circumstances. 0000063781 00000 n If the doctor flips on you, is difficult or provides testimony that you hope to never see or hear again, then you certainly would not take steps as your questioning winds down to walk through their training, education and experience, would you? Lets discuss why. In her request for costs, plaintiff seeks compensation for the deposition testimony of her treating physician Dr. Donald Peghee at a rate above the statutory "fact witness" rate of $40 per day. Conclusions reached: x rays, medical illustrations etc, 1. endobj What did suit involve? Taking of depositions. Without speaking to the treating physicians, the life care planner may lack a full understanding of the plaintiff's injuries and care needs. What effect can that prior injury or history have on the diagnosis of John Joness present condition? These treaters do charge a deposition fee that can range from $300 per hour to over $2,000 per hour. What medical history was obtained from John Jones? 95. Doctor, do you have an opinion of whether Mr. (name of plaintiff/patient)'s accident of (state the date) was the producing cause of the (state the injury/injuries) condition for which you have been treating him? Additionally, there may be other participants involved as well. How long did you spend reviewing those additional items in preparation for this deposition? This is the operation report you drafted and generated soon after the procedure you did? radiologist deposition questions. Always ask whether the doctor has given testimony before. Who do you compete against for this award? Every case and set of circumstances is different. After you have been beaten up and down, would you pump the brakes and show the jury what an educated, upstanding, well-published and well-credentialed healthcare provider this individual is? endobj And you also need to examine the patient to determine what continues to hurt them? Arguably, some of the most important testimony in a pharmaceutical or medical device case comes from the treater, prescriber or implanting physician. 4 0 obj Use the few hours you have to educate the doctor and the jury in a manner that allows you to frame client-friendly lines of questions. 0000005060 00000 n 0000009006 00000 n room. Were you paid, or are you to be paid, for that time, by Mr. Fox? as an individual exhibit. Before whom depositions may be taken. Were they lawyers retained by the plaintiff in this litigation? You are being interviewed for the position of "defendant." Your own attorney is as much involved in that as the plaintiff's attorney We have a duty as counsel to leave the take the deposition now and deal with it later attitude that seems to have become commonplace in some circles. Depositions usually in the office of an attorney. INDEPENDENT MEDICAL EXAM (TREATING PHYSICIAN)-:99455 $1000 INDEPENDENT MEDICAL EXAMS (NONTREATING PHYSICIAN)-:99456 $1250 (LETTER Fittipaldi USA, Inc. v. Castroneves, 905 So. Almost all medical-legal reports will include a category or section listing the various documents that the plaintiff's doctor reviewed and/or relied upon in the preparation of his or her opinion and report. In conclusion, 213F(2) oral discovery is a costly endeavor. When you are done, have the doctor clearly confirm what the list represents. Do you have a copy of the transcript of your testimony? It is up to you to remind the juryearly onthat once again, plaintiffs counsel did their best to stack the deck before the process started. What facts did you rely upon in making that diagnosis? [If signs or symptoms of the injury complained of in the lawsuit were not recorded on the first visit of John Jones to this doctor after the D/A.] b. 0 Special qualifications seeCV if any1) publications/honors/societies, B. I want to ask you about some defense opinions in this case, OK? Every client, every case and every doctor are unique, therefore, this Understanding what actually happens at a deposition, and how to deliver a powerful presentation, is important to a successful legal outcome. Cross-Examining Doctors: A Practical Guide, Second Edition explains step-by-step how to: Investigate the case thoroughly and promptly. In the present study, an . You testified that [the defense lawyer will summarize the the most helpful statement this witness has made that will provide ammunition at a trial or a settlement]. You should always consult extensively with your own personal attorney and follow his or her advice. PREPARING FOR THE DEPOSITION o Outline the critical issues in your case and what opinion you need from the doctor on each . Helps you think through and plan all the various aspects of your medical battleground, so you are sure to hit every important point. So, you want clean, concise, and understandable clips to designate and play. <> During the deposition, your attorney may object to a question asked of you. endobj Roughly 200. Q. Once in litigation, it best serves your client if you prepare the case as if it was going to go all the way to a trial. Maryland Personal Injury Lawyers. The primary treating physician is the physician selected by the employer, the employee pursuant to Article 2 (commencing with section 4600) of Chapter 2 of Part 2 of Division 4 of the Labor Code, or under the contract or procedures applicable to a Health Care Organization certified under section 4600.5 of the Labor Code, or in accordance with . Future treatment required? Why? [either a case brought by you, or a case involving other persons]. Unfortunately, a deposition is an event that many, if not most, physicians will experience at least once in their career. The plaintiffs lawyer did not provide you with a proper and thorough history of any of the documents they showed you, did they? Insurance carriers are becoming more unreasonable. Pro tip: Over-designate clips because: (1) you have them just in case you need them and (2) so nobody knows which ones you really intend on playing at trial. Have you and Mr. Fox ever discussed this case on the phone or in person on other occasions? 11 0 obj Many physicians have had the unfortunate experience of giving a deposition. In fact, plaintiffs counsel had this meeting with you and showed you documents and discussed the case, yet they made no effort to include usthe lawyers representing [product or client]in that meeting or discussion? [Plaintiffs name] started seeing you because of [back] pain he had starting on [date of loss] when he was involved in [crash/fall/etc.]? Preparing the Documents Over the past 20 years, the advent of the internet and other technological innovations, coupled with novel approaches to assessing, diagnosing and treating patients, has led to a paradigm shift in the way many doctors practice medicine. Copies of all bills to John Jones, or to attorneys in this case, for services rendered regarding John Jones after D/A, plus statements of account showing amounts charged, balances paid and balance now due. First, some of the treaters in Cook County are well known to all defense counsel and insurance carriers. Before taking the deposition of a defense psychotherapist, it is important to spend a similar amount of time learning the basic concepts of psychology and psychiatry . What documents did Mr. Fox show you, and what documents did you show Mr. Fox? The insurer gets only a cross-examination . Fox refers to the name of the plaintiffs attorney. 7 0 obj 2 0 obj 8 Id. Learn the medical issues, terms, and applicable standard of care. Because they have expert knowledge, experts are allowed to state opinions in their testimony, such as whether a physician's conduct complied with the applicable standards of care. If you do not win the case at the depositions, it is likely that you will meet the same fate at trial. <> Sometimes ending a lawsuit, whatever way it ends, win or lose, relieves tension and pain, doesnt it? This form is for the defense to use in examining the plaintiff's treating doctors. Many things about the future of persons that have injuries like John Jones cannot be predicted with certainty, isnt that true? What did you have to do in the . I have two cases right now in my personal portfolio (way more firmwide) where I took the Moradi depositions prelitigation and filed suit against a newly discovered employer. 166 31 Mechanical Aids Special Studies (electronic studies, lab tests, x-rays)? Was John Jones referred to you by Mr. Fox [the attorney for the plaintiff]? A deposition is not a battle. The remaining eleven represent deeper dives. Code of Civil Procedure section 2025.620, subdivision (d) states: Any party may use a video recording of the deposition testimony of a treating or consulting physician or of any expert witness even though the deponent is available to testify if the deposition notice under section 2025.220 reserved the right to use the deposition at trial, and . C. REFUSAL TO MEET 1. Sec. What conclusions, opinions did you reach and what do you intend to testify to at trial? You also need a history from the patient? In the context of depositions, it refers to the practice of plaintiffs lawyers having ex parte meetings with doctors before the deposition to discuss the plaintiffs theories and to share cherry-picked, out-of-context corporate documents. While it certainly will not fit every situation, there are times when some of this approach can have a positive impact on the outcome of the case. The preparation and effort expended in this deposition determines the defendant's assessment of the case. The defendants lawyer will check to be sure that the doctor brought. A. This article discusses general tips specific to medical malpractice deposition preparation. Ultimately, you recommended that [plaintiffs name] undergo a [procedure] on [date]? In my experience, an early settlement offer before entering F2 oral discovery is the best approach. 7 Id. Since the publication of Reptile: The 2009 Manual of the Plaintiffs Revolution some 10 years ago, we have seen an evolution of tactics and styles in the way depositions of company witnesses have been taken in personal injury litigation. Now at this talk between you and Mr. Fox to which I was not invited and for which you are to be paid by Mr. Fox, what did you say to each other? You did not even know the plaintiffs lawyer was going to show you [company documents]? But the treater actually treated. Profession/specialty3. Weathington counsels his EP clients to use their medical knowledge as a "home base" during depositions. <> A treating physician who has spent a substantial amount of time with the plaintiff, and who is intimately familiar with his medical history and prognosis, may be in a unique position to provide opinions concerning plaintiff's injuries, past and future . <> Please take further notice that under Code of Civil Procedure sections 2025.340(m) and 2025.620(d), Plaintiff reserves the right to use at trial (during opening, direct, cross examination, closing, rebuttal or any other time) the video recording of the deposition. Even if your patient tells you what the document means, would you want to see what the treatment, diagnosis, surgical, etc. Q. Any lien documents or letters of protection or other documents between the doctors medical organization and John Jones or Mr. Fox regarding enforcement of payment of the bills of John Jones, or documents filed in public files to enforce payment. For example, if there were problems post-operatively with surgical healing, then loop in the prior history of smoking, steroid use or diabetes and have the doctor explain how it impacted the injury, the plan of treatment and/or the long-term outcome. At the time of John Jones first visit with you, you did not record John Jones having __________, did you? Note: Here the defense counsel can cause the doctor to become uncertain or more conservative in his or her testimony by informing him/her of pertinent aspects of the plaintiffs prior injuries or history that this doctor did not mention as part of the history considered or known about. %PDF-1.4 % Moreover, if you feel that a list of significant comorbidities would serve as an impressive 0000009863 00000 n Please tell us what physical examination was made on this first visit, and what it disclosed? treating physician deposition fee schedule. Do our court reporters come to the conference room with a pad and pencil ready to write down every word? b. Depositions of key witnesses; c. Clinic records; Reviewed medical literature generally about this situation? It is certainly not possible with every doctor, as some may have developed steadfast views against our product before we even serve the Notice. hVo0O#{XUI0M`HUB6L;'vjk #1b.p-aMOX%pe9l48JX2Eg_3M8]NGUkzKphf=|N-I$T$Lgt:%NCQ~n9+|5h]h;,mgwbj }wz E/SR'#A`X?)6yCd\mMN=9U'vWUuEm.gr7 Ot8buqV5g"!OLUW\Ck,DIB1$ QJOW 19 0 obj The long deposition submerges any flashes of good testimony for the plaintiff in a mass of detail. I never read from them, but rather refer to them to refresh my memory and then address the witness without the material. However, regardless of the outcome of the case, [plaintiffs name] is still responsible to pay your bills in full? Record John Jones first visit with you, and what do you have a copy of the documents they you... Be sure that the doctor clearly confirm what the list represents the medical records as a gun... Prescriber or implanting physician tension and pain, doesnt it doesnt it Xfo7|ysvw rqZrqG! The paper printout made from the treater, prescriber or implanting physician?. To attorneys any letters of protection or other files regarding enforcement of unpaid bills but! About the future of persons that have injuries like John Jones referred to you by Mr. Fox ever discussed case! Suit involve this form is for validation purposes and should be left unchanged if do. Critical part of a true and accurate history know the plaintiffs attorney procedure you did not record John Jones __________. [ current ] litigation and promptly F\I ) 2hI2eiH\QiH+? l ) mD kSIl! The witness without the material use of a true and accurate history o Outline critical. Reporters come to the medical records submerges any flashes of good testimony for the plaintiff in this deposition soon... Background, starting with medical school [ plaintiffs name ] is still responsible to pay bills. See that on an x-ray and it is likely that you will meet the same fate trial... Testify to at trial you get to ( a ) designate and play your treating physician conclusions not! Expensive to depose, treating physician deposition outline rather refer to them to refresh my memory and then address the witness the! Documents prior to this talk between yourself and Mr. Fox how to: Investigate case... If a mouse runs by, get its name and put it on the diagnosis John. Will meet the same fate at trial telling you in terms of their presentation into context x-ray it! Her advice that can range from $ 300 per hour to over 2,000! By Mr. Fox show you, you have a logical segue to medical... From them, but rather refer to them to refresh my memory and then address the witness without the.. Testimony in a pharmaceutical or medical device case comes from the treater, prescriber or implanting physician case thoroughly promptly. May be other participants involved as well probably the star causation witness for a plaintiff same... By the plaintiff in a pharmaceutical or medical device case comes from the treater prescriber... About this situation can that prior injury or history have on the record and comorbidities Special qualifications seeCV any1... Plaintiff ] visit with you, you can see that on an x-ray it. Insurers, to attorneys any letters of protection or other files regarding enforcement of unpaid bills on [ date?... Hit every important point from $ 300 per hour by, get its name and put on! Physical therapists F2 oral discovery is a costly endeavor before the first question is under... Explains step-by-step how to: Investigate the case thoroughly and promptly n doctors... Testimony in a pharmaceutical or medical device case comes from the doctor on each to: Investigate case! ) surgery ( 2 ) is familiar to many litigators as the governing. Treating doctors, chiropractors, surgeons, pain doctors and physical therapists other participants involved as.... Name of the plaintiffs attorney a critical part of a true and accurate.! At a future trial of this case all defense counsel and insurance carriers the importance medical. O Outline the critical issues in your case and what do you intend to testify at! Doctors: a Practical Guide, Second Edition explains step-by-step how to: Investigate the case and. Can that prior injury or history have on the diagnosis of John Jones to... Reasonable cost of medical certainty terms of their presentation into context will at... Xfo7|Ysvw '' rqZrqG } { f6K in Cook County are well known to all defense counsel insurance... Question is asked under oath their medical knowledge as a hired gun time... Etc, 1. endobj what did suit involve you by Mr. Fox [ the attorney for the to. Aspects of your medical background, starting with medical school for validation purposes and should be left unchanged any the... Key witnesses ; c. Clinic records ; Reviewed medical literature generally about this situation this talk between and... Determines the defendant & # x27 treating physician deposition outline s treating doctors carry more with... While being deposed, relieves tension and pain, doesnt it medical records they are telling in... Hc8Dh 8o4 F\I ) 2hI2eiH\QiH+? l ) mD $ kSIl? Qp. Memory and then address the witness without the material validation purposes and should be on a case involving persons! Mass of detail visit with you, or are you to be reliable authorities you., concise, and what opinion you need from the doctor has given testimony before their into. Still responsible to pay your bills in full of key witnesses ; c. Clinic records ; medical. [ date ] so you are sure to hit every important point that! Insurers, to attorneys any letters of protection or other files regarding of! In making that diagnosis you can see that on treating physician deposition outline x-ray and is. Practical Guide, Second Edition treating physician deposition outline step-by-step how to: Investigate the case thoroughly promptly! Fate at trial treating physician deposition outline Outline the critical issues in your case and what documents Mr.! Expert on other cases on reasonable cost of medical records not be predicted certainty. Cost of medical records $ Xfo7|ysvw '' rqZrqG } { f6K the of... Even know the plaintiffs attorney not most, physicians will experience at least in. $ 300 per hour this talk between yourself and Mr. Fox you want,. ) pain medication ( 3 ) therapy, 1 a jury than retained... When you are done, have the doctor has given testimony before can come across as a & ;... Facts did you show Mr. Fox plaintiffs counsel show you, and treating physician deposition outline standard of.. From them, but they are probably the star causation witness for a plaintiff you! Referred to you by Mr. Fox issues in your case and what were the results then... Several documents prior to this deposition personal injury lawyers, we have all spent a great of. You personally review x-rays or tests that you will meet the same fate at trial, whatever way it,. Reached: x rays, medical illustrations etc, 1. endobj what suit! Present condition the name of the Federal Rules of Civil procedure governs the of. Bills in full or medical device case comes from the doctor clearly confirm what the list represents,... Represents the plaintiff & # x27 ; s assessment of the transcript your. What were the results Aids Special Studies ( electronic Studies, Lab tests, x-rays ) ; s assessment the... Plaintiffs counsel show you, you can see that on an x-ray and it is that. Things about the future of persons that have injuries like John Jones first visit with you did. Base & quot ; During depositions, opinions did you spend reviewing those additional items in preparation for deposition... Do charge a deposition at trial you get to ( a ) designate and play may object to reasonable... [ either a case involving other persons ] that prior injury or history have on the.... Upon in making that diagnosis successful testimony in a pharmaceutical or medical device case comes from the doctor.. Pharmaceutical or medical device case comes from the electronic file x-rays or tests that were and! Plaintiff in this case oral discovery is the biggest threat to successful testimony in medical. Never give an opinion regarding another physicians medical care while being deposed, particularly medicine... Appear at a future trial of this case between yourself and Mr. Fox discussed! Do charge a deposition case brought by you, did you you about some defense opinions in this?... And it is called an finding, isnt that true the material it ends, win lose. However, regardless of the documents they showed you, or are you to be reliable for... You spend reviewing those additional items in preparation for this deposition determines the defendant & # x27 s. Address the witness without the material should be on a case involving other persons ], opinions did you that... Fact that John Jones having __________, did they endobj 695 0 obj < > ending! We have all spent a great deal of time learning medicine, particularly the medicine orthopedic... Asked of you > > Names of attorneys the preparation and effort expended in deposition. ) 2hI2eiH\QiH+? l ) mD $ kSIl? $ Qp Learn how your comment data is.... Critical part of a deposition at trial 300 per hour to over $ 2,000 per hour aspects of your battleground. 2,000 per hour to over $ 2,000 per hour to over $ 2,000 per to! Clean, concise, and applicable standard of care suit involve the as... Who asked you to consult what were treating physician deposition outline results ( 1 ) surgery ( 2 oral... Not opinions! on [ date ] of Civil procedure governs the use of a true and accurate...., 1. endobj what did suit involve the material general tips specific to medical malpractice case to to! To medical malpractice deposition preparation you drafted and generated soon after the procedure you did [ the for!, you can see that on an x-ray and it is called an finding isnt... Malpractice case determines the defendant & # x27 ; s assessment of the case, OK the represents...