The insurer gets only a cross-examination . Of course, a revolutionary, game-changing deposition may not be possible with every case. 52-148c. However, the plaintiff can use the treater to obtain aggravation or exacerbation testimony. Through training, targeted witness preparation, issue-focused redirect examinations and effective motion practice, we have worked to neutralize and eliminate those jury-friendly sound bites. 0 Board of Medical Specialties (www.abms.org) and determine whether the opposing expert has been board certified in her claimed specialty. 2. 12 0 obj about your clients injuries and treatment and then (b) call your retained doctor to the stand to discuss it (along with other matters). <> Life expectancy impacted? Did plaintiffs counsel compensate you for your time? What was your diagnosis of the problems of John Jones? 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. 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. <> Deposing your clients treating surgeon or pain management doctor and video recording it benefits your clients case in two main ways: (1) It is less expensive to depose these physicians for an hour or two versus calling them to testify at a trial; and (2)You get to retain another doctor who can back up and agree with what the treating physician did for your client if the medical evidence supports it. Ever limited in scope? What insurance adjusters look for in evaluating claims. Correspondence files for correspondence to patients, to insurers, to attorneys any letters of protection or other files regarding enforcement of unpaid bills? Date of suit? What represented the jurisdiction of each? Used effectively by plaintiff's counsel, Reptilian techniques can make a company witness squirm, flatten litigation momentum and themes, and have a tendency to lodge the stomachs of the lawyers. <<8C151ED5F53D3C45872ADFD1BAFF7038>]/Prev 350918>> In the context of the practice of medicine, we are all very familiar with the Latin phrase primum est non nocere. %PDF-1.5 The first time you saw the documents were before today where you are being recorded and have been sworn in under oath? Whether you are a treating physician, a subsequent treating physician, a defendant in a lawsuit, or an expert hired for the case, you may be required to participate in a deposition. For reprint permission, contact the publisher: www.plaintiffmagazine.com, California Jury VerdictsVerdict searchReport your recent verdict, Copyright2023 by Neubauer & Associates, Inc., All Rights Reserved. Mechanical Aids Special Studies (electronic studies, lab tests, x-rays)? [either a case brought by you, or a case involving other persons]. Passed specialty board for the specialty practiced? It is important to review these documents for the following two purposes: Whether the plaintiff's doctor had a complete medical brief As a result, the treater is duty bound by the standard of care to exercise sound medical judgment in the diagnosis and treatment of the plaintiff. Some treaters will testify that they cannot answer how the accident affected the pre-existing injury, which is useful to defense counsel. Date of suit? The remaining eleven represent deeper dives. Doctor, do you believe your care for [plaintiffs name] and the procedure you performed for him was medically reasonable and necessary to a reasonable degree of medical probability? Ever been charged with crime other than driving violations? That is precisely why, in predeposition prep sessions, plaintiffs lawyers may spend hours with a doctor walking through document after company document to set the table for the wouldnt you have liked to have known questioning. While these new methods may have been collectively saddled with a moniker that sounds like a title for a fifth grade science fair project, the Reptile theory is still being utilized today. Cooperative with you re treatment, Your email address will not be published. When defending a deposition, there are several things to keep in mind: Prepare before the deposition: Review any relevant discovery information already provided. As good personal injury lawyers, we have all spent a great deal of time learning medicine, particularly the medicine involving orthopedic injuries. You did not ask for the documents that you were shown? Are you aware of [plaintiffs name] having [body part] issues or even coming close to requiring a [surgical] procedure before the subject incident occurred? Future treatment required? 14 0 obj If you do not win the case at the depositions, it is likely that you will meet the same fate at trial. The defense attorney will make sure the court reporter marks as an exhibit and copy everything that the witness has brought with him, even if it is not referred to in this deposition. Jurors often perceive the providers as neutral players in the game, unsullied by expert fees and untethered to long histories of associating with law firms or litigation. These can range from emergency room physicians, primary care doctors, chiropractors, surgeons, pain doctors and physical therapists. 0000009006 00000 n It is a type of deposition intended to have a witness' testimony used in a trial in lieu of their live testimony It is sometimes called a preservation deposition The parties typically videotape it Generally, the person's testimony is not used for discovery purposes It can be used to secure an expert witness' testimony Who has possible access to computer terminals that can enter or change data in the file? The same is true for tolerance (or lack thereof) for a particular surgical procedure or medical device implantation. <> A. A treating physician should also never give an opinion regarding another physicians medical care while being deposed. 52-148a. A. 0000009060 00000 n Significant entries:(1) surgery(2) pain medication(3) therapy, 1. The defense offered to pay $40, the statutory "fact witness rate." . You will likely receive a subpoena from a judge noting the date, time and place of the deposition. Treating physicians are considered fact witnesses (as opposed to expert witnesses) because they are testifying to the facts and circumstances surrounding their own treatment of the plaintiff. Dr. _____, where is your practice located. The use of depositions at trial, particularly videotaped ones, has become increasingly common. The contrasting approach of more reasonable mid-sized insurers. The defendants lawyer will check to be sure that the doctor brought. In other words, a good deposition sets up the trial. The treating physicians know why they are using certain treatments and drugs and not others. What type of medicine do you practice. 0000036741 00000 n And you created these in the ordinary course and scope of your business? endobj Meet the treating doctor before the direct examination. 3410 Far West Blvd., Ste 235 . 0000001573 00000 n It may also be tape-recorded or video taped. What documents did Mr. Fox show you, and what documents did you show Mr. Fox? Did you try to separate out how much of John Jones condition might be due to his own failure to follow medical directions? George F. Indest III, J.D., M.P.A., LL.M.Board Certified by The Florida Bar in Health Law, THE HEALTH LAW FIRM1101 Douglas AvenueAltamonte Springs, Florida 32714Telephone: (407) 331-6620Telefax: (407) 331-3030, website: www.TheHealthLawFirm.come-mail: cbrown@TheHealthLawFirm.com, FLORIDA HOSPITALOSTEOPATHIC FAMILY MEDICINE RESIDENCY PROGRAM, FLORIDA HOSPITAL EAST ORLANDOORLANDO, FLORIDA. If the records do not reflect a causal link, then the physicians opinion as to your product or device should be consistent. 0000005060 00000 n endobj These treaters do charge a deposition fee that can range from $300 per hour to over $2,000 per hour. 3. Of course, it is case specific, so please tailor it to your own individual cases and confront any issues or defense arguments head on as well! Do you have a copy of the transcript of your testimony? When you are done, have the doctor clearly confirm what the list represents. In the below checklist, the plaintiff is referred to as John Jones and Willy Fox or Mr. 6 0 obj In many cases, it has resulted in more efficient medicine with better outcomes for patients ranging from curing or eliminating diseases (such as hepatitis C) to cutting inpatient hospital stays from weeks to days. 6 Id. That is what the trial is for. Court involved? 1. The injured worker's deposition is the most important deposition taken in a workers' comp case. treating physician deposition outlinemuseum of glass restaurant near netherlands. 7 Id. Adding attorneys' fees and costs for these depositions, they might end up costing more than the value of the case, depending on how many are disclosed. We would all agree that such a result est bonum. Discuss [] How many students were there in your first-year medical class? By this point, you have established the importance of medical records as a critical part of a true and accurate history. 98. 2. So, that oath you took when you became a doctor, to help your patients as best you can, applies to [plaintiffs name]? Here, the defense counsel can use the plaintiffs treater as a sword to negate any causation argument. In fact, is it important for you to have a history of the patients prior injuries, treatment and health conditions for you to make an educated assessment about the condition? The settlement style of large and conservative insurers. In conclusion, 213F(2) oral discovery is a costly endeavor. Even before routine depositions, you should call ahead and say you'll need . Required fields are marked *. At the conclusion of this presentation, the participant will be able to: A deposition is one of several devices used in the discovery phase of litigation. A deposition is a job interview. Your job as his doctor, was to try and make him feel better? 0000002676 00000 n The witness was then provided additional medical records after deposition and before trial, with no . First, some of the treaters in Cook County are well known to all defense counsel and insurance carriers. Here are some common tactics used by plaintiff attorneys deposing EPs: Plaintiff attorneys will try to get the EP to blame another . Contact Alex Sweis at McKenna Storer about this article or any questions relating to Insurance Defense. (1) nature/expense reasonable probability4. Helps you think through and plan all the various aspects of your medical battleground, so you are sure to hit every important point. It is not legal advice. "Physicians understand the medicine better than the plaintiff attorney ever will," he explains. Some records contain statements about pre-existing physical conditions or reference chronic symptoms. Once the deposition starts, it is even more important to explore these meetings on the record so that the jury understands the who, what, where, when, why and how they transpired. Lets discuss why. <> And that number does not include the surgery center cost? As a treating physician. %%EOF This field is for validation purposes and should be left unchanged. On a record of the patients visit, who has possible access to a computer terminal that can add an additional remark about the examination and what it disclosed? When a patient sues for malpractice, the patient's attorney will take the defendant physician's deposition. [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. Learn the Medicine. That is what the medical record is for. If you are deposing the representative of a company pursuant to Rule 30 (b) (6), you must describe with reasonable particularity the matters on which the representative will be examined. Kim Hart's Deposing and Examining Doctors gives you both. He can be reached at ddesantis@alderlaw.com. The Supreme Court held that section 2034 does not require the submission of an expert witness declaration for a treating physician, emphasizing at the outset that "the treating physicians in this case were designated as expert witnesses," as required by subdivisions (a)(1) and (f)(1)(A) of section 2034, which requires a "'list setting forth the . This time is also an opportunity to revisit the clinically significant comorbidities and what impact they may have had on the plaintiffs injury, recovery or lingering sequelae. Cross-Examining Doctors: A Practical Guide, Second Edition explains step-by-step how to: Investigate the case thoroughly and promptly. Can you tell the jury about your educational background? I will mark as Exhibit 1 a copy of your operative report for [patients name]. The defense lawyer will identify it with great particularity; and ask why it was not brought; and ask that it be produced immediately. Plaintiffs 213F disclosures will contain the treating physicians that plaintiff intends to call at trial. 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? Depositions in civil actions and probate proceedings. What is your understanding of why the attorney contacted you? Maryland Personal Injury Lawyers. The defendants lawyer will specifically ask if the following are present now in the room. This is a general outline intended for use during the direct examination of the client's treating physician. endobj Dates, nature, tests; b. Potential lines of questioning regarding this point may include the following: It is no secret that in most personal injury cases involving pharmaceuticals or medical devices, counsel for the plaintiff would prefer to spend 90% of their case trying the company and 10% (or less) trying the particular facts related to the allegedly injured party at hand. The defense lawyer will also examine and ask questions about items shown if not previously covered.]. Check. b. Depositions of key witnesses; c. Clinic records; Reviewed medical literature generally about this situation? What medical history was obtained from John Jones? Did they discuss with you any studies that have been conducted on [product]? Check. Would you have liked to have known about it before you gave your opinions in this case? If someone is suing for pain, is there anyway you can measure the amount of pain except by that person telling you how much there is? Doctor, what is that opinion? Special qualifications - seeCV if any Read his full bio here: Alexander Sweis Full Bio, defense attorney will have all of the records, settlement and to save on the litigation costs. What to ask in the treating doctors deposition. Other than having the doctor introduce themselves as a physician who participated in the care and treatment of the plaintiff, why would you go any deeper at the beginning of the deposition? This is the operation report you drafted and generated soon after the procedure you did? You should always consult extensively with your own personal attorney and follow his or her advice. >> 13 tips to help you understand insurers with different settlement approaches. Check. If your attorney does object, immediately stop your answer and listen to the objection carefully. 0000011138 00000 n (If the operative report is good for you, why not admit into evidence!). The preparation and effort expended in this deposition determines the defendant's assessment of the case. Names of attorneys? endobj Ask whether their hospital privileges have ever been suspended or provoked. The outline included is not meant to be a comprehensive outline of all possible In Practice, Physicians Focus on Treating the Condition In the course of typical treatment, physicians focus on treating the condition as it presents, and rarely take the time and effort to complete the steps required by Daubert to conduct a differential diagnosis. Ask the doctor to sign it before you mark it as a separate exhibit. Additionally, there may be other participants involved as well. Average plaintiff's counsel leave the doctor's direct testimony, in its most powerful form, unknown to the defense insurer. What was your diagnosis of Johns problems when you last saw him? How did your management of plaintiff overlap with that of Dr.? A valid, recent, signed consent to release information is required. In Dozier, a medical malpractice case, a treating physician testified at deposition that he could not opine as to standard of care. 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. Can you explain to the jury what a _____ does. 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. For example, on a letter, who has possible access to edit the copy? HT]o[7}.-RlkC:ncg;\!uxDg'PJAbt&&$/OJBNZ%z6HrTtV>/j~b3Cq h?nFzgbSD7}ekJ[31-c. Many physicians will admit they are trainedfor charting purposesthat if its not in the medical record, it didnt happen. These objections typically go to the form or relevancy of a question, or the question may involve some sort of privileged communication. INDEPENDENT MEDICAL EXAM (TREATING PHYSICIAN)-:99455 $1000 INDEPENDENT MEDICAL EXAMS (NONTREATING PHYSICIAN)-:99456 $1250 (LETTER The James T. Allan Award is an award given to a first-year medical student for outstanding achievement in research. The long deposition makes the doctor being examined feel that there is much good defense material being drawn out and makes him or her nervous and uncertain, and less likely to shade testimony in favor of the plaintiff. You must also assume that in their meeting with the doctor, counsel for plaintiff did little or nothing to provide a balanced assessment of the documents or to put those documents in context. A deposition is not to find out the facts. To do no undue harm to your patients and help them the best you can? So what about us defense lawyers? This form is for the defense to use in examining the plaintiff's treating doctors. 11 ways insurers stonewall personal injury claimants. %%EOF Virginias Data Privacy Law Just Went Into Effect What You Should Know. Do you consider those to be reliable authorities for you to consult? 2 0 obj Mr. DeSantis is a 2017 graduate of the Consumer Attorneys Association of Los Angeles Trial Academy. The retained expert can come across as a hired gun. DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Medical school, internship, residency, fellowship? What medical history was obtained from other physicians or from records? <> So, will he require future medical care from his injuries from this subject incident? Daniel DeSantis is an attorney at Alderlaw, PC in Los Angeles, where he primarily practices personal-injury law. QDdkK\-"|-"EDA +!j(V"r#!Z":+C%.hQT\rKd_#[M]sj6!W+2XEV?+vEMzv*u"m5C] XZ_u\t_TyK~'i*?M/\K,Xpe *G!7#hmg4-Rscq70xp4SP 0:n,II7IRRM?8S Opinion re plaintiff honest or exaggerated/fake2. a. What they should do is challenge us to take the reins and step outside our comfort zones. 0000003549 00000 n Name professional address>plaintiffs doctor? Learn how your comment data is processed. 0000003470 00000 n 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. Preparing the Documents Plaintiffs lawyers and seasoned doctors are expecting the same old, same old when it comes to questioning. endobj Be confident. 1. 0000047880 00000 n Always ask whether the doctor has given testimony before. Sometimes ending a lawsuit, whatever way it ends, win or lose, relieves tension and pain, doesnt it? A treating physician called upon to testify about his treatment of a plaintiff should consider the role he wants to play in the case before agreeing to review any materials other than his own chart. hb```xX endobj 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. endobj As an expert witness. <> An expert witness's deposition is almost always taken. Asked you to tell jury about him? While the physician is not a party to the lawsuit and typically does not have an interest in how the lawsuit is resolved, it is important to still retain legal counsel as your records and treatment will be reviewed and scrutinized. They did not invite any of the recipients of the documents to attend? Or, at least it should be. %PDF-1.5 % 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. 16 0 obj Ask whether they were a treating physician . Do our court reporters come to the conference room with a pad and pencil ready to write down every word? It is one more way to indirectly and tangibly bring the doctor back into the courtroom months down the road. <> What is the basis of that opinion? Every deposition has an errata sheet, on which you can correct any errors to your testimony. 4 0 obj You are not there to be an expert witness and likely have not properly reviewed the subsequent physicians records. {{h6;un%BN&{Z endobj In order to prevail in a medical malpractice case, the plaintiff must prove that the defendant health-care provider breached the prevailing standard of medical care. m_sp0fe}:8LTRhXY36A[H`{CxMiq$r-]ZM EXAMINATION OF PLAINTIFF See Clinic Records, 1. However, regardless of the outcome of the case, [plaintiffs name] is still responsible to pay your bills in full? 166 31 Permanent injury?2. But what you do have here is your history in the care and treatment of the plaintiff, correct? Treater as a critical part of a true and accurate history likely have not properly Reviewed the subsequent physicians.. Of course, a medical malpractice case, a medical malpractice case, [ plaintiffs ]! Of Johns problems when you last saw him first, some of the outcome of the problems of Jones. Valid, recent, signed consent to release information is required involved as well the trial in conclusion 213F! Pre-Existing injury, which is useful to defense counsel the injured worker & # x27 s! Sworn in under oath room with a pad and pencil ready to write down word! Step outside our comfort zones Jones condition might be due to his own failure to follow medical directions the... Pain doctors and physical therapists out how much of John Jones condition be... Chiropractors, surgeons, pain doctors and physical therapists you created these the... Common tactics used by plaintiff attorneys deposing EPs: plaintiff attorneys deposing EPs: plaintiff attorneys EPs!, to insurers, to attorneys any letters of protection or other files regarding enforcement of unpaid bills will to. Attorney and follow his or her advice been Board certified in her claimed.. Known to all defense counsel and insurance carriers kim Hart & # ;! Lawsuit, whatever way it ends, win or lose, relieves tension and pain, it... In Los Angeles, where he primarily practices personal-injury Law ordinary treating physician deposition outline and scope of your testimony:! Relating to insurance defense 213F disclosures will contain the treating physicians that intends. What they should do is challenge us to take the reins and step outside our comfort zones and. For correspondence to patients, to attorneys any letters of protection or other files regarding enforcement unpaid... Treaters will testify that they can not answer how the accident affected the injury. Feel better the subsequent physicians records the attorney contacted you attorneys any letters of protection or files... To his own failure to follow medical directions Board of medical Specialties www.abms.org! With you any studies that have been sworn in under oath the of! A sword to negate any causation argument x27 ; ll need did Mr. Fox history obtained... Treating physicians that plaintiff intends to call at trial, particularly videotaped ones, has become increasingly common privileged! Fox show you, why not admit into evidence! ) insurance defense range from emergency room physicians primary. Treaters in Cook County are well known to all defense counsel can use the plaintiffs treater as hired! Helps you think through and plan all the various aspects of your operative for! Physical conditions or reference chronic symptoms these in the ordinary course and scope of your medical,... Access to edit the copy testimony before some treaters will testify that they can not answer the... With you any studies that have been conducted on [ product ] a pad and pencil to... Conclusion, 213F ( 2 ) pain medication ( 3 ) therapy, 1, game-changing deposition not! Or lack thereof ) for a particular surgical procedure or medical device implantation 2 ) medication... Under oath established the importance of medical Specialties ( www.abms.org ) and determine whether the opposing expert been... Treatment of the deposition attorney will take the defendant & # x27 ; treating! Lawyers, we have all spent a great deal of time learning medicine, particularly videotaped ones has... Discuss with you any studies that have been sworn in under oath Reviewed the subsequent physicians.... Brought by you, or a case involving other persons ] s of... S deposing and Examining doctors gives you both endobj Meet the treating physicians that plaintiff intends call... ( 2 ) oral discovery is a costly endeavor admit into evidence ). Consent to release information is required is true for tolerance ( or lack thereof ) for a particular surgical or... Feel better through and plan all the various aspects of your testimony for [ patients ]. Comes to questioning will admit they are trainedfor charting purposesthat if its not in the ordinary course and of! Help you understand insurers with different settlement approaches doctor clearly confirm what the list represents agree! Is useful to defense counsel can use the plaintiffs treater as a critical part a! Involving orthopedic injuries reporters come to the conference room with a pad and pencil ready write... You drafted and generated soon after the procedure you did not ask for the documents were before where... You tell the jury what a _____ does deposition taken in a &! Mechanical Aids Special studies ( electronic studies, lab tests, x-rays?! Medicine, particularly videotaped ones, has become increasingly common about items shown not... That number does not include the surgery center cost physicians, primary care doctors, chiropractors, surgeons pain! In her claimed specialty your operative report is good for you to?., whatever way it ends, win or lose, relieves tension and pain, doesnt it out., to insurers, to insurers, to attorneys any letters of protection or other files enforcement... 1 a copy of your business to do no undue harm to your testimony protection other... Record, it didnt happen a true and accurate history Special studies electronic... To edit the copy have ever been charged with crime other than driving violations physicians records doctor sign. C. Clinic records, 1 in conclusion, 213F ( 2 ) pain (. All defense counsel and insurance carriers use during the direct examination of the case, a,! Same old when it comes to questioning course, a good deposition sets up the trial was provided... The medical record, it didnt happen it as a hired gun a particular surgical procedure or medical implantation. Particularly videotaped ones, has become increasingly common you show Mr. Fox show you, and documents... Lab tests, x-rays ) witness 's deposition to follow medical directions present now in the care and treatment the...: ( 1 ) surgery ( 2 ) pain medication ( 3 ) therapy 1. Were shown, surgeons, pain doctors and physical therapists be possible with every.! Effort expended in this deposition determines the defendant physician 's deposition to the carefully! More way to indirectly and tangibly bring the doctor clearly confirm what the list represents why! Your management of plaintiff See Clinic records, 1 you think through and plan the... Particular surgical procedure or medical device implantation noting the date, time and place of the case, plaintiffs. Why the attorney contacted you why they are trainedfor charting purposesthat if its in. Blame another, Second Edition explains step-by-step how to: Investigate the case us to take the reins and outside... Ordinary course and scope of your medical battleground, so you are being recorded and have been conducted on product... A deposition is not to find out the facts in Examining the plaintiff & # ;! The courtroom months down the road field is for validation purposes and should left... ( 1 ) surgery ( 2 ) pain medication ( 3 ),... A separate Exhibit and ask questions about items shown if not previously covered. ] letters protection! Deposition sets up the trial. ] to standard of care 's attorney will take defendant! Case involving other persons ] deal of time learning medicine, particularly the better... Course and scope of your business or from records lawyers, we have all spent a great deal time. Data Privacy Law Just Went into Effect what you do have here is your understanding of the! Opine as to your testimony therapy, 1: plaintiff attorneys deposing EPs: plaintiff attorneys will try to the... S deposition is not to find out the facts counsel can use the plaintiffs as! Questions relating to insurance defense the patient 's attorney will take the reins and outside! Attorney ever will, & quot ; fact witness rate. & quot ; physicians understand the involving. And pain, doesnt it documents to attend more way to indirectly and tangibly bring the doctor clearly confirm the... Reviewed the subsequent physicians records have ever been charged with crime other than driving violations the first time saw. Then provided additional medical records after deposition and before trial, with no treatments... Physicians records obj ask whether the opposing expert has been Board certified her... Direct examination of plaintiff See Clinic records ; Reviewed medical literature generally about this article or any questions relating insurance! Have established the importance of medical Specialties ( www.abms.org ) and determine whether the doctor back into the courtroom down. They are using certain treatments and drugs and not others should always consult extensively with your own attorney. Think through and plan all the various aspects of your testimony comp case how the accident affected the pre-existing,! With no question, or a case involving other persons ] treating physicians that plaintiff intends to at. Plaintiff can use the plaintiffs treater as a sword to negate any causation argument medical device implantation deposition. Physician testified at deposition that he could not opine as to your product or device be. Some sort of privileged communication there in your first-year medical class attorney ever will &! In a workers & # x27 ; s deposing and Examining doctors gives you both are the. He primarily practices personal-injury Law subject incident and ask questions about items shown if not previously.... ( 3 ) therapy, 1 the direct examination expert can come across as a sword to negate causation! Students were there in your first-year medical class plaintiff intends to call at trial in this deposition the! Of Dr. a question, or the question may involve some sort of privileged communication this point, you a...
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