Direct-Examination of Dr. Jackson (Treating Doctor)

QUALIFICATIONS

• FULL NAME AND BUSINESS ADDRESS
• TELL US ABOUT YOUR EDUCATIONAL BACKGROUND
• WHERE DID YOU GO TO MEDICAL SCHOOL?
• WHEN DID YOU GRADUATE?
• WHERE DID YOU DO YOUR RESIDENCE?
• WHERE WERE YOU EMPLOYED AFTER YOUR RESIDENCY?
• HOW LONG HAVE YOU BEEN IN PRIVATE PRACTICE?
• BRIEF SUMMARY OF YOUR PRIVATE PRACTICE ?
• WHAT TYPE OF MEDICAL DOCTOR ARE YOU ?
• WHAT IS ORTHOPEDICS ?
• DO YOU PERFORM SURGERIES?
• HOW OFTEN ?
• DO YOU HAVE HOSPITAL PRIVILEGES ?
• ARE YOU BOARD CERTIFIED IN ANY SPECIALTY?
• EXPLAIN EXACTLY WHAT BOARD CERTIFICATION IS
• ARE ALL DOCTORS BOARD CERTIFIED?
• HAVE YOU BEEN QUALIFIED TO TESTIFY AS AN EXPERT BEFORE?

OFFER DR. JACKSON AS AN EXPERT IN ORTHOPEDIC SURGERY

THIS PARTICULAR CASE

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• BEFORE TESTIFYING TODAY, HAVE YOU HAD THE CHANCE TO REVIEW MR. MONROE MEDICAL RECORDS?
• WHAT RECORDS DID YOU REVIEW ?
  Go through all of them, priors and post records
• DID YOU RELY ON THOSE RECORDS IN FORMING YOUR OPINION?
• MR. MONROE WAS A PATIENT OF YOUR OFFICE BEFORE THIS ACCIDENT?
• WHEN WAS THE LAST TIME YOU SAW HIM BEFORE THIS ACCIDENT?

ER REPORTS

• DIRECTING YOUR ATTENTION TO THE ER REPORTS, WHAT WERE HIS COMPLAINTS IN THE ER?
• WHAT DID THE ER DRS DO FOR HIM?
• WHAT WERE HIS DISCHARGE INSTRUCTIONS?

DR. JACKSON

• WHERE WAS THE NEXT PLACE HE WENT FOR TREATMENT (His office on 6/28/01)?
• WHAT WERE HIS COMPLAINTS TO YOUR OFFICE IMMEDIATELY FOLLOWING THE ACCIDENT?
• WHAT DID THE EXAM REVEAL?
• WHAT THE DIAGNOSIS?
• WHAT TREATMENT WAS RECOMMENDED?
• 6/18/01 HOW WAS HE DOING ON THE JUNE 18TH VISIT?
• WHAT WERE YOUR RECOMMENDATIONS AT THAT TIME?
• 7/31/01 HOW WAS HE DOING ON THIS VISIT?
• WHAT WERE YOUR RECOMMENDATIONS?
• 9/4/01 HOW WAS HE DOING?
• 11/13/01 HOW WAS HE DOING IN NOVEMBER?
• WHAT DID YOU RECOMMEND AT THAT TIME?
• 3/23/02 HOW WAS HE DOING THE LAST TIME YOUR OFFICE TREATED HIM?

BALTIMORE CITY THERAPY

HE HAD THERAPY AT HEALTHSOUTH, CAN YOU DESCRIBE FOR US WHAT TYPE OF TREATMENT HE WAS RECEIVING THERE?

DR. JONES’ RECORDS

• DID YOU REVIEW DR. JONES’ RECORDS?
• HOW WAS HE DOING WHEN DR. JONES SAW HIM ON 11/20/03?
• HAD HIS CONDITION CHANGED SINCE YOU SAW HIM IN MARCH OF 02?
• WHAT DID DR. JONES RECOMMEND?
• WHAT DID THAT THERAPY INVOLVE?

OPINIONS

• DO YOU HAVE AN OPINION WITHIN A REASONABLE DEGREE OF MEDICAL PROBABILITY WHAT INJURIES, EDWARD MONROE SUSTAINED AS A RESULT OF THE 5/18/03?
• WHAT IS THAT OPINION?
• DO YOU HAVE AN OPINION WITHIN A REASONABLE DEGREE OF MEDICAL PROBABILITY AS TO WHETHER THOSE INJURY IS A PERMANENT INJURY?
• WHAT IS THAT OPINION?
• DO YOU HAVE AN OPINION AS TO WHETHER HE HAD A PRE-EXISTING CONDITION BEFORE THIS ACCIDENT?
• WHAT IS THAT OPINION?
• WAS HE MORE SUSCEPTIBLE TO AN INJURY BECAUSE OF HIS AGE?

MEDICAL BILLS

ARE YOU FAMILIAR WITH THE LOCAL CHARGES FOR HOSPITAL VISITS, PHYSICAL THERAPY AND ORTHOPAEDIC SURGEONS CHARGE?

MEDICAL BILLS AND REPORTS BINDER

More Sample Outlines

• Another expert direct
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