Medical Deposition Outline for Injury Case

Outline for Medical Deposition.doc

Put objections on tape


Qualifications of doctor

Name, profession and address

License to practice in State

How long engaged in practice

Medical training


Member of Medical Societies

Member of Hospital Staffs



Have occasion to treat plaintiff in this case.


I retained you to review mr. Loner’s films several weeks ago

Have you reviewed his films?

Have you ever met ed loner.

Is it necessary to meet the patient to do your job,

is it beneficial

have you reviewed any of his medical records?

Would that be helpful at all?

Did you prepare a written report

What films did you look at

Identify as exhibits and tender.

What is the earliest film you reviewed from mr. Loner?

What were the circumstances of that visit.

What did it show.

Can you show the jury where that is

What was the next film?

What does that tell us about the condition of his spine?

Have you read materials on trauma tears in the vertebrates

What is the disk made of is it strong?

What would it take to herniate it.

What is degenerative disk disease

What is arthritis in the back

You are not a surgeon right

Don’t operate on people.

You specialize in reading xrays, mris and cat scans

More qualified than a surgeon to do that right

Have you been retained by my firm in the past in the course of representing clients?

Have you ever done work for mr. Rickards old firm. Chambers mabry and mcclelland?

You have been paid by my client to examine mr. Loners films.

How does that affect your judgment and opinion on the evidence.

How much of your business involves reviewing films were the patient is not involved in lawsuit and you are doing it from a healing standpoint.


First time saw plaintiff

Examination at that time

Where examination held

Was plaintiff cooperative


History from plaintiff

History from other sources

Physical Examination

Nature of plaintiff’s complaints

Inquiry as to limitation of motion

Results of inquiry

Was the possible presence of pain an essential

part of the diagnosis

Did you attempt manipulation of injured part

If so, what findings

Did plaintiff complain of pain during


Describe area and location of same

Displacement – if so, describe

Mechanical Aids

X-rays of plaintiff

If so, were these taken under your supervision

direction and control

Will you interpret same in your possession

What do x-rays show

Point out areas indicating existence of abnormality

Pain and Suffering

Did patient complain of pain in the first examination

Upon what factors is opinion as to existence of pain based

Are a and location of pain as described by plaintiff

Do you have any opinion you can state with reasonable medical

certainty as to whether the pain is real or simulated

If so, state

Anything in examination to cause you to disbelieve complaints of plaintiff


State diagnosis based on findings as a result of examination

What objective symptoms

Explain what is meant by objective symptoms

What subjective symptoms

What is meant by subjective symptoms

*Do you have any opinion as to the consistency of patient’s history to

 the injury he sustained

What is that opinion

Were the complaints in proportion to your findings



What treatment administered to plaintiff

How long and with what frequency did such treatments continue


Was plaintiff hospitalized

If so, for how long

How often saw plaintiff in hospital


Surgery on plaintiff


Subsequent surgery


Nature and extent of drugs and medicines required in treatment of


Plaintiff still on drugs


Did plaintiff undergo physiotherapy.  If so, what type

For how long period of time were treatments rendered and by whom

Did plaintiff undergo psychotherapy

If so, describe

For how long a period of time

Pain During Treatment

Was plaintiff in pain during course of treatment

Was plaintiff disabled during treatment

Was pain constant or of a recurring nature

Disability During Treatment

Was plaintiff disabled during treatment

If so, to what extent

Last Examination

Last time examined by plaintiff

Condition at that time

Was plaintiff observed to be in pain at that time

Character and severity of pain at that time

Plaintiff still disabled at that time

To what extent

Plaintiff still require use of mechanical therapeutic device


Future treatment and expense of same

Do you have an opinion you can state with reasonable medical

certainty the length of time such treatment will have to continue and the

probable necessary expense of thee treatments

Future pain and suffering

     ***        Do you have an opinion you can express with reasonable medical certainty

as to whether plaintiff will in the future continue to suffer pain as a result of his injuries

Will you so state

On what factors do you base your opinion in this respect

Future Disability/Limitations

         *Can you state with reasonable medical certainty whether plaintiff will

have permanent disability (or continue temporary disability)

If so, will you please give us your best estimate as to the percentage of


Statement for Services

Have you rendered a bill to plaintiff for services

Amount of bill

Is this reasonable for like services in this area

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