Medical Deposition Outline for Injury Case


**Put objections on tape

Qualifications of doctor

  1. Name, profession and address
  2. License to practice in State?
  3. How long engaged in practice?
  4. Medical training
  5. Specialties
  6. Member of Medical Societies
  7. Member of Hospital Staffs
  8. Boards
  9. Authorships
  10. Have an occasion to treat the plaintiff in this case?


  1. I retained you to review Mr. Loner’s films several weeks ago have you reviewed his films?
  2. Have you ever met ed loner?
  3. Is it necessary to meet the patient to do your job
  4. is it beneficial
  5. have you reviewed any of his medical records?
  6. Would that be helpful at all?
  7. Did you prepare a written report
  8. What films did you look at
  9. Identify as exhibits and tender.
  10. What is the earliest film you reviewed from Mr. Loner?
  11. What were the circumstances of that visit?
  12. What did it show?
  13. Can you show the jury where that is
  14. What was the next film?
  15. What does that tell us about the condition of his spine?
  16. Have you read materials on trauma tears in the vertebrates
  17. What is the disk made of is it strong?
  18. What would it take to herniate it?
  19. What is degenerative disk disease
  20. What is arthritis in the back
  21. You are not a surgeon right
  22. Don’t operate on people.
  23. You specialize in reading X-rays, MRIs, and cat scans
  24. More qualified than a surgeon to do that right
  25. Have you been retained by my firm in the past in the course of representing clients?
  26. Have you ever done work for Mr. Rickards old firm? Chambers Mabry and McClelland?
  27. You have been paid by my client to examine Mr. Loner’s films.
  28. How does that affect your judgment and opinion on the evidence?
  29. 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.


  1. First time saw plaintiff
  2. Examination at that time
  3. Where examination held
  4. Was plaintiff cooperative


  1. History from the plaintiff
  2. History from other sources

Physical Examination

  1. Nature of plaintiff’s complaints
  2. Inquiry as to limitation of motion
  3. Results of inquiry
  4. Was the possible presence of pain an essential part of the diagnosis
  5. Did you attempt manipulation of the injured part
  6. If so, what findings
  7. Did the plaintiff complain of pain during fractures
  8. Describe the area and location of same
  9. Displacement? – if so, describe

Mechanical Aids

  1. X-rays of plaintiff
  2. If so, were these taken under your supervision, direction, and control
  3. Will you interpret the same in your possession
  4. What do x-rays show
  5. Point out areas indicating the existence of abnormality

Pain and Suffering

  1. Did the patient complain of pain in the first examination
  2. Upon what factors is opinion as to the existence of pain based
  3. Are a and location of pain as described by plaintiff
  4. Do you have any opinion you can state with reasonable medical certainty as to whether the pain is real or simulated
  5. If so, state
  6. Anything in examination to cause you to disbelieve complaints of the plaintiff


  1. State diagnosis based on findings as a result of examination
  2. What objective symptoms
  3. Explain what is meant by objective symptoms
  4. What subjective symptoms
  5. What is meant by subjective symptoms
  6. *Do you have any opinion as to the consistency of patient’s history to the injury he sustained
  7. What is that opinion
  8. Were the complaints in proportion to your findings



  1. What treatment administered to the plaintiff
  2. How long and with what frequency did such treatments continue


  1. Was plaintiff hospitalized
  2. If so, for how long
  3. How often saw plaintiff in hospital


  1. Surgery on plaintiff
  2. Describe
  3. Subsequent surgery


  1. Nature and extent of drugs and medicines required in the treatment of the plaintiff
  2. Plaintiff still on drugs


  1. Did the plaintiff undergo physiotherapy?  If so, what type
  2. For how long period of time were treatments rendered and by whom
  3. Did the plaintiff undergo psychotherapy
  4. If so, describe
  5. For how long a period of time

Pain During Treatment

  1. Was plaintiff in pain during the course of treatment
  2. Was plaintiff disabled during treatment
  3. Was pain constant or of a recurring nature

Disability During Treatment

  1. Was plaintiff disabled during treatment
  2. If so, to what extent

Last Examination

  1. Last time examined by plaintiff
  2. Condition at that time
  3. Was the plaintiff observed to be in pain at that time
  4. Character and severity of pain at that time
  5. Plaintiff still disabled at that time
  6. To what extent
  7. Plaintiff still require the use of a mechanical therapeutic device


Future treatment and expense of same

  1. 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

  1.  ***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
  2. Will you so state
  3. On what factors do you base your opinion in this respect

Future Disability/Limitations

  1. *Can you state with reasonable medical certainty whether the plaintiff will have a permanent disability (or continue temporary disability)
  2. If so, will you please give us your best estimate as to the percentage of disability

Statement for Services

  1. Have you rendered a bill to the plaintiff for services
  2. Amount of bill
  3. Is this reasonable for like services in this area