Medical Deposition Outline for Injury Case
Put objections on tape
Qualifications of doctor
Name, profession and address
License to practice in State
How long engaged in practice
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
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
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
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 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
*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