Plaintiff Attorney Legal Information CenterQUALIFICATIONS 
- FULL NAME AND BUSINESS ADDRESS
- WHAT KIND OF DOCTOR ARE YOU
- DO YOU TREAT PATIENTS WITH TRAUMATIC BRAIN INJURIES
- WHAT DO YOU DO HERE AT JSANDONS HOPKINS
- WHAT DO YOU MEAN BY COGNITIVE IMPAIRMENT ISSUES
- WHAT DOES IT MEAN TO BE THE DIRECTOR OR THE RESIDENTS
- WHAT TYPES OF THINGS DO YOU DO TO STAY CURRENT IN YOUR FIELD
- EDITOR
- RESEARCH/GRANTS
- CME COURSES
- WHERE DID YOU GO TO MEDICAL SCHOOL
- WHERE DID YOU DO YOUR RESIDENCY, WHAT FIELD
- WHERE DID YOU DO YOUR FELLOWSHIP, WHAT FIELD
- ARE YOU BOARD CERTIFIED IN ANY SPECIALTY?
- ARE ALL DOCTORS BOARD CERTIFIED
- HAVE YOU GIVEN LECTURES IN THE FIELD OF NEUROLOGY
- LECTURES IN THE FIELD OF COGNITIVE IMPAIRMENT
- HAVE YOU WRITTEN ARTICLES IN THE AREA OF NEUROLOGY
- HAVE YOU WRITTEN ARTICLES IN THE AREA OF COGNITIVE IPAIRMENT
- HAVE YOU HELD ANY TEACHING POSITIONS IN NEUROLOGY
- HELD ANY TEACHING POSITIONS IN COGNITIVE IMPAIRMENT
- GIVE US AN IDEA OF THE TYPES OF PROBLEMS YOUR PATIENTS HAVE
- WHAT % OF YOUR PATIENTS THAT YOU TREAT HAVE A BRAIN INJURY
- DO YOU TRY AND STAY CURRENT WITH ADVANCEMENTS IN YOUR FIELD
- WHY DO YOU SPEND SO MUCH TIME EDUCATING YOURSELF AS A DOCTOR
- EXHIBIT BRADY 1 CV ADMIT AND OFFER
- OFFER DR. BRADY AS AN EXPERT IN NEUROLOGY WITH A SPECIALTY IN COGNITIVE IMPAIRMENT
ANATOMY NEUROLOGY 101
- EXHIBIT BRADY 2
- DOES THIS PICTURE FAIRLY AND ACCURATELY SHOW THE ANATOMY OF THE BRAIN
- WOULD THIS PICTURE HELP YOU IN EXPLAINIGN YOUR OPINIONS TO THE JURY
- MOVE TO ADMIT BRADY 2
- DESCRIBE THE DIFFERENT LAYERS IN THE BRAIN
- THE FRONTAL LOBES, WHAT DO THEY HELP US WITH
- WHAT IS AN AXON
- EXHIBIT BRADY 3
- DOES THIS PICTURE FAIRLY AND ACCURATELY SHOW THE ANATOMY OF AN AXON AND SHEARING
- WOULD THIS PICTURE HELP YOU IN EXPLAINIGN YOUR OPINIONS TO THE JURY
- MOVE TO ADMIT BRADY 3
- HOW DO OUR AXONS WORK AND HELP US
- WHAT IS AXONAL SHEARING
- HOW DOES AXONAL SHEARING HAPPEN IN A CAR CRASH
- WHEN THE TAIL OF THE AXON IS DAMAGED WHAT HAPPENS TO OUR ELECTRICAL IMPULES
- DIAL UP TO DSL OR A FRAYED ELECTRIC WIRE
- IF YOU DO AN MRI OR A CAT SCAN WILL THAT AXONAL SHEARING SHOW UP IMMEDIATELY?
- EXHIBIT BRADY 4
- DOES THIS PICTURE FAIRLY AND ACCURATELY SHOW THE ANATOMY OF THE BRAIN
- WOULD THIS PICTURE HELP YOU IN EXPLAINING YOUR OPINIONS TO THE JURY
- MOVE TO ADMIT BRADY 4
- WHAT IS A HEMMORAGHIC CONTUSION
- CAN A HEMMORAGHIC CONTUSION HAPPEN IN A CAR CRASH
- SHOW US WHERE THE HEAD OF THE CELL LIVES
- WHERE DOES THE TAIL OF THE CELL LIVE
- IS A HEMMORAGHIC CONTUSION SOMETHING YOU CAN SEE ON AN MRI OR CAT SCAN
- IS A HEMMORAGHIC CONTUSION A BLEED IN YOUR BRAIN
FOUNDATION FOR RECORDS
- BEFORE GIVING OPINIONS IN THIS CASE, HAVE YOU REVIEWED ALL THE MEDICAL RECORDS AVAILABLE, INCLUDING THE HOSPITALIZATIONS, DR. SANDO’S RECORDS THE MRI’S, ALL THE RECORDS FROM THE JSANDONS HOPKINS DOCTORS, DR. WARD, AND THE RECORDS FROM THE NATIONAL REHABILITION HOSPITAL
- DID YOU REVIEW THE BILLS FOR THOSE SERVICES
- DID YOU REVIEW MR. WATTS MEDICAL RECORDS FROM BEFORE THE ACCIDENT
- DID YOU RELY UPON YOUR REVIEW OF THOSE RECORDS IN FORMING YOUR OPINIONS
WHAT DO CT SCANS AND MRI’S OF OUR BRAIN SHOW
More Information
- EXHIBIT BRADY 5
- DESCRIBE WHAT WE ARE LOOKING AT THIS
- THIS IS MR. WATT’S CT SCAN ON THE DAY OF THE INCIDENT
- EXHIBIT BRADY 6
- THIS ONE OF MR. WATT’S MRI’S AFTER THE ACCIDENT
- DID YOU REVIEW ALL THE FILMS IN MR. WATT’S CASE INVOLVING HIS BRAIN
- DID YOU REVIEW AL THE THEM PERSONALLY, NOT JUST THE REPORTS
- DID YOU AGREE WITH ALL THE REPORTS
- DID YOU REVIEW THE FILMS WITH A NEURORADIOLOGIST AS WELL
- WHY DID YOU DO THAT
- DO THESE IMAGES FAIRLY AND ACCURATELY SHOW THE IMAGES TAKEN OF MR. WATT’S BRAIN FOLLOWING THE COLLISION OF NOVEMBER 4, 2009
- MOVE AND ADMIT BRADY 5-6
BREAKING DOWN A HEAD INJURY AND CLIENT’S RECORDS
- CAN YOU DESCRIBE FOR US THE PHASES OF A HEAD INJURY INVOVLING AXONAL SHEARING OR A BLEED ON THE BRAIN
- IS IT UNUSUAL FOR A PERSON TO FEEL NORMAL AND THEN GET LOOPY
- DID YOU HAVE A CHANCE TO READ MR. WATT’S DEPOSITION
- FOLLOWING THE ACCIDENT HE FELT OK AND THEN LATER WENT TO THE ER ONLY AFTER PEOPLE AROUND HIM NOTICED HE WAS ACTING STRANGE, IS THAT UNUSUAL
- DOCTOR’S HOSPITAL TREATMENT EXHIBIT BRADY A
- THE DX FRROM DOCTORS COMMUNITY HOSPITAL WAS A CLOSED HEAD INJURY, DESCRIBED AS HEMMORAGE – INTRACRANIAL TRAUMATIC
- WHAT DOES THAT MEAN?
- DO YOU AGREE WITH THAT DX
- I WANT TO GO THROUGH SOME OF THE COMPLAINTS MR. WATT REPORTED AT THE HOSPITAL AND ASK YOU IF THEY ARE SYMPTOMS OR SIGNS OF A HEAD INJURY
- HEADACHES
- UPSET STOMACH
- NOT THINKING CLEARLY
- DESCRIBES THINGS AS FOGGY
- FUZZY THINKING
- DIFFICULTY CONCENTRATING
- TROUBLE REMEMBERING THINGS
-
- THE RECORDS MENTION THAT HE HAS AN ABRASION ON HIS FOREHEAD, IS THAT CONSISTENT WITH HEAD TRAUMA
- THE AIR BAG DEPLOYED IN HIS CAR, CAN AN AIR BAG CAUSE HEAD TRAUMA
- WHAT HAPPENS TO YOUR BRAIN WHEN YOUR HEAD GOES BACK AND FORTH VERY QUICKLY
- DOCTORS HOSPITAL DID A CT SCAN OF HIS HEAD AND WHAT DID THE CT SCAN REVEAL
- EXHIBIT
BRADY B - WHEN THE ER DOCTORS AT DRS COMMUNITY HOSPITAL SAW THE BRAIN INJURY, THEY TRANSFERRED HIM TO WASHINGTON HOSPITAL CENTER
WASHINGTON HOSPITAL CENTER EXHIBIT BRADY C
- WASHINGTON HOSPITAL CENTER DID NOT DO ANY ADDITIONAL SCANS BUT WHEN THEY DISCHARGED HIM, THE DISCHARGE DIAGNOSIS WAS TRAUMATIC BRAIN INJURY, DO YOU AGREE WITH THAT?
- DID THEY GIVE HIM DISCHARGE INSTRUCTIONS FOR A HEAD INJURY
- MR. WATT CONTINUED TO HAVE PROBLEMS WITH HIS HEAD AND HIS FAMILY DOCTOR ORDERED AN MRI OF HIS BRAIN, WAS THAT REASONABLE TO DO EXHIBIT BRADY D IS 05/10 AND E IS 11/10
DR. SANDO EXHIBIT BRADY F
- THE FIRST NEUROLOGIST THAT SAW MR. WATT WAS DR. SANDO IN JANAURY OF 2008, WAS HE STILL COMPLANING OF ALL THESE PROBLEMS WHEN HE FIRST WENT TO SEE DR. SANDO?
- DID DOCTOR SANDO ASSURE HIM THAT HE THOUGHT THE PROBLEMS WOULD GO AWAY?
- WAS HE STILL HAVING THESE PROBLEMS EVEN A YEAR LATER IN JANUARY OF 2009
- BY THIS TIME SOME OF HIS PROBLEMS DEVELOPED INTO THINGS LIKE HAVING A HARD TIME FOLLOWING A NOVEL, OR HAVING PROBLEMS WITH HIS MOODS AND ABILITY TO HAVE “FILTER” BEING KURT WITH PEOPLE AND BEING VERY SHORT
- ARE THESE ALSO SYMPTOMS THAT CAN BE ASSOCIATED WITH A BRAIN INJURY TO THE RIGHT FRONTAL LOBE
COGNATIVE REHABILITATION
- YOU FIRST SAW MR. WATT ON APRIL, 3 2011 EXHIBIT BRADY G
- WHAT WERE HIS COMPLAINTS TO YOU AT THAT TIME
- WAS HE STILL HAVING HEADACHES
- DID YOU DO ANY TESTING ON HIM ON THAT DATE
- WHAT WAS YOUR ASSEMENT OF HIM ON THAT DATE
- YOU SAY THAT THE PROBLEM IS SEVERY COMPARED TO HIS PREVIOUS BASELINE, WHAT DO YOU MEAN BY THAT
- WHAT WAS YOUR DIAGNOSIS
- WHAT RECOMMENDATIONS DID YOU MAKE FOR HIM
- DID HE FOLLOW-THROUGH AND GO TO NRH FOR REHAB
- HOW DOES REHAB HELP
- TELL US HOW COGNITIVE REHABILITATION WORKS
- SAW HIM AGAIN ON JUNE 24 2011 EXHIBIT BRADY H
- WAS HE STILL HAVING THE SAME PROBLEMS,
- WAS HE STILL HAVING HEADACHES
- YOU ALSO MENTION IN YOUR REPORT, PROBLEMS HE WAS HAVING WITH EXECUTIVE FUNCTIONS, WHAT DOES THAT MEAN?
- HOW CAN PROBLEMS WITH EXECUTIVE FUNCTIONS IMPACT SOMEONE
HOW WOULD IT IMPACT A COLLEGE PROFESSOR
- HOW, IF AT ALL, IS YOUR ANALYSIS OF HIS CONDTION IMPACTED BY THE FACT HE IS A PH.D TEACHING ENGLISH LITERATURE
- THE LAST TIME YOU SAW HIM IN JANUARY OF 2012 EXHIBIT BRADY I, HOW WAS HE DOING
- WHAT IF ANY PROBLEMS WAS HE STILL HAVING
- WAS HE SEEING ANYONE ELSE OTHER THAN YOU AT THE TIME
- WHO IS DR. RAO,
- WHAT DEPARTMENT IS SHE IN
- WHAT IS SHE TREATING HIM FOR
- WHAT IS HER DIAGNOSIS
- DO YOU KNOW A DR. KORTEE
- HOW DO YOU KNOW HER?
- IS SHE CURRENTLY TREATING MR. WATT
- WHAT DOES SHE DO
- HOW LONG CAN A PERSONS PROBLEMS LAST FOLLOWING A HEMMORACHIC CONTUSION
- DESCRIBE HOW AFTER AN INJURY TO THE BRAIN HAS HEALED A PERSON MAY STILL HAVE PROBLEMS AS A RESULT OF THE ORIGINAL INJURY
PRIOR MEDICAL RECORDS
- DID YOU REVIEW MEDICAL RECORDS OF MR. WATT FROM BEFORE THE CRASH OF NOVEMBER 4, 2009
- DID MR. WATT SUFFER FROM ANY PROBLEMS WITH HEADACHES
- DID MR. WATT SUFFER FROM ANY COGNITIVE IMPAIRMENT
- DID HE EVER HAVE A HEAD INJURY BEFORE NOVEMBER 4, 2009
- WHAT ABOUT ANY BEHAVIORAL OR MOOD PROBLEMS BEFORE NOVEMBER 4, 2009
- HAVE YOU FORMED OPINIONS IN THIS CASE?
- HAVE THOSE OPINIONS BEEN FORMED BASED UPON YOUR TRAINING AND EXPEREINCE, A REVIEW OF ALL THE MEDICAL RECORDS, A REVIEW OF THE FILMS IN THIS CASE PERSONALLY AND YOUR EXAMINATION AND TREATMENT OF MR. WATT?
- DO YOU FIND THE PUBLICATION MARKED AS EXHIBIT 7 IS PUBLICATION THAT IS A RELIEABLE AUTHORITY ON THE SUBJECT OF TRAUMATIC BRAIN INJURIES AND HAVE YOU RELIED UP THIS PUBLICATION IN FORMING YOUR OPINIONS TODAY.
- DO YOU FIND THE PUBLICATION MARKED AS EXHIBIT 8 IS PUBLICATION TO BE A RELIEABLE AUTHORITY ON THE SUBJECT OF THE TREATMENT OF HEADACHES AND HAVE YOU RELIED UP THIS PUBLICATION IN FORMING YOUR OPINIONS TODAY.
- DO YOU HAVE AN OPINION WITHIN A REASONABLE DEGREE OF MEDICAL PROBABILITY AS TO WHETHER OR NOT MR. WATT SUFFERED FROM A HEAD INJURY AS A RESULT OF THE NOVEMBER 4, 2009 CAR CRASH
- WHAT IS THAT OPINION?
- DO YOU HAVE AN OPINION WITHIN A REASONABLE DEGREE OF MEDICAL PROBABLILITY AS TO WHETHER OR MR. WATT SUSTAINED A HEMMORAGHIC CONTUISION AS A RESULT OF THE NOVEMBER 4, 2009 CAR CRASH
- WHAT IS THAT OPINION
- DO YOU HAVE AN OPINION WITHIN A REASONABLE DEGREE OF MEDICAL PROBABLILITY AS TO WHETHER OR MR. WATT SUSTAINED AXONAL SHEARING AS A RESULT OF THE NOVEMBER 4, 2009 CAR CRASH
- WHAT IS THAT OPINION
- DO YOU HAVE AN OPINION WITHIN A REASONABLE DEGREE OF MEDICAL CERTAINTY AS TO WHETHER OR NOT TREATMENT RENDERED BY DOCTORS COMMUNITY HOSPITAL, WASHINGTON HOSPITAL CENTER, DR. SANDO, THE TREATMENT HERE AT JHH, INLCUDING YOUR TREATMENT, THE TREATMENT BY NATIONAL REHABILITATION CENTER AND THE CT SCAN AND MRI’S OF HIS BRAIN, WERE ALL NECESSARY, REASONABLE AND CAUSALLY RELATED TO THE CRASH OF NOVEMBER 4, 2009
- WHAT IS THAT OPINION
- EXHIBT BRADY 9 DO YOU HAVE AN OPINION WRDMC AS TO WHETHER OR NOT THE BILLS SUMMARIZED HERE BEFORE IN THE AMOUNT OF $569,582.23 ARE FAIR REASONABLE NECESSARY AND CAUSALLY RELATED TO THE NOVEMBER 4, 2009 CRASH
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