Have an occasion to treat the plaintiff in this case?
Examination
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 X-rays, 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. Loner’s 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 the lawsuit and you are doing it from a healing standpoint.
General
First time saw plaintiff
Examination at that time
Where examination held
Was plaintiff cooperative
History
History from the 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 the injured part
If so, what findings
Did the plaintiff complain of pain during fractures
Describe the 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 the same in your possession
What do x-rays show
Point out areas indicating the existence of abnormality
Pain and Suffering
Did the patient complain of pain in the first examination
Upon what factors is opinion as to the 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 the plaintiff
Diagnosis
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
Treatment
General
What treatment administered to the plaintiff
How long and with what frequency did such treatments continue
Hospitalization
Was plaintiff hospitalized
If so, for how long
How often saw plaintiff in hospital
Operations
Surgery on plaintiff
Describe
Subsequent surgery
Drugs
Nature and extent of drugs and medicines required in the treatment of the plaintiff
Plaintiff still on drugs
Therapy
Did the plaintiff undergo physiotherapy? If so, what type
For how long period of time were treatments rendered and by whom
Did the plaintiff undergo psychotherapy
If so, describe
For how long a period of time
Pain During Treatment
Was plaintiff in pain during the 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 the 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 the use of a mechanical therapeutic device
Prognosis
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 the 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 the plaintiff will have a permanent disability (or continue temporary disability)
If so, will you please give us your best estimate as to the percentage of disability
Statement for Services
Have you rendered a bill to the plaintiff for services
“I am thankful for all Chris Simon and his team have done for my daughter and I would recommend him to anyone who has been injured or lost a loved one due to an accident.”
– Christianne Smith
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