Whether you are a treating physician, a subsequent treating physician, a defendant in a lawsuit, or an expert hired for the case, you may be required to participate in a deposition. Names of parties? The first time you saw the documents were before today where you are being recorded and have been sworn in under oath? Maryland Personal Injury Lawyers. It makes it easier if the records ultimately go back to the deliberation room to be broken down and separatedmuch easier than an unwieldy stack of hundreds of pages of records. The defense offered to pay $40, the statutory "fact witness rate." . Learn the Medicine. This point has significance for the diagnosis or treatment of John Jones, doesnt it? Check. Case factors which suggest plaintiff fraud. [ 11 0 R] We will equip you with the knowledge required to prevail. This needs to be done before the defense deposition. Here is my guide for direct examination of the treating doctor. 0000008212 00000 n 2017 April. PREPARING FOR DEPOSITIONS A. Depositions as Part of an Overall Discovery Plan 1:50 Reviewing the Case 1:51 Establishing Goals 1:52 Preparing an Outline 1:52.1 Practice Tip: When Making a Deposition Outline, Should You Write Out Every Question? Did plaintiffs counsel say or suggest we were invited but did not show up? A deposition is the questioning of a witness under oath outside of a courtroom. Lets discuss why. 2. The injured worker's deposition is the most important deposition taken in a workers' comp case. 2. Did they discuss with you any internal company documents? It is not uncommon for a treating physician giving a deposition to have little or no independent recollection of the plaintiff or of their treatment of the plaintiff. What is the basis of that opinion? The deposition of the defendant physician is the crucial turning point of your medical negligence case. Butler Snow LLP var today = new Date(); var yyyy = today.getFullYear();document.write(yyyy + " "); | Attorney Advertising, Copyright var today = new Date(); var yyyy = today.getFullYear();document.write(yyyy + " "); JD Supra, LLC. And we can live our lives and see these degenerative changes on MRI and never have pain? endobj When court order necessary. You wouldnt want to guess about those things, would you? The deposition is taken down by a court reporter and a typed transcript is produced for later use by the attorneys and the court. Average plaintiff's counsel leave the doctor's direct testimony, in its most powerful form, unknown to the defense insurer. Testified in any deposition or at trial before? While the physician is not a party to the lawsuit and typically does not have an interest in how the lawsuit is resolved, it is important to still retain legal counsel as your records and treatment will be reviewed and scrutinized. about your clients injuries and treatment and then (b) call your retained doctor to the stand to discuss it (along with other matters). Did you try to separate out how much of John Jones condition is due to his prior injury/history and how much is due to the accident he is suing about? That being the case, for you to fully understand that document and be educated on itlike a medical recordwould you need a proper and thorough history of that document? 0000003806 00000 n ?4bm9MQFc:=R%`h0QO1{W~}Cxw1# 4Dzu[Zd.6/|D`^m^ :7 Will the doctors, hospitals and other medical facilities wait for payment if I am unable to pay my bills as they are incurred? They want to treat. The term Secondary Gain in medicine means The gain derived from an illness, such as personal attention and service, monetary gains, disability benefits, and release from unpleasant responsibilities, doesnt it? 0000000916 00000 n Copies of all bills to John Jones, or to attorneys in this case, for services rendered regarding John Jones after D/A, plus statements of account showing amounts charged, balances paid and balance now due. By Mike A. D'Amico, Esq.July 2012 In short, yes. As good personal injury lawyers, we have all spent a great deal of time learning medicine, particularly the medicine involving orthopedic injuries. At the time of John Jones first visit with you, you did not record John Jones having __________, did you? How long did you spend reviewing your own medical records in preparation for this deposition? That is what the medical record is for. A treater who sees a claimant only once or twice may not be worth the litigation expenses because he is not a significant treater. These treaters are the physicians who treated the plaintiff for his alleged injuries. 1. The defense attorney will identify on the records all exhibits that doctor has brought. Your job as his doctor, was to try and make him feel better? %%EOF Having now laid the foundation for the plaintiffs health condition and having taken a trip through time leading up to the allegations at issue, you must then make the call to determine how deep you want to go regarding substantive opinions about the product, outcomes, diagnosis and prognosis. Contact Alex Sweis at McKenna Storer about this article or any questions relating to Insurance Defense. The James T. Allan Award is an award given to a first-year medical student for outstanding achievement in research. Jurors often perceive the providers as neutral players in the game, unsullied by expert fees and untethered to long histories of associating with law firms or litigation. C. Cannot depose Independent Medical Examination Doctor or treating doctors, in the absence of special circumstances. This requires that they engage in continuous self-examination to ensure that their testimony represents the facts of the case. Your attorney may object simply for the record and then tell you to go ahead and answer the question; or he may object and instruct you not to answer. Please show me all the items you brought to comply with that subpoena. Through training, targeted witness preparation, issue-focused redirect examinations and effective motion practice, we have worked to neutralize and eliminate those jury-friendly sound bites. Checklist of items to maintain and bring in. A deposition is frequently used at trial to impeach a witness who testifies differently than their deposition testimony at trial. Surgeons are expensive to depose, but they are probably the star causation witness for a plaintiff. George F. Indest III, J.D., M.P.A., LL.M.Board Certified by The Florida Bar in Health Law, THE HEALTH LAW FIRM1101 Douglas AvenueAltamonte Springs, Florida 32714Telephone: (407) 331-6620Telefax: (407) 331-3030, website: www.TheHealthLawFirm.come-mail: cbrown@TheHealthLawFirm.com, FLORIDA HOSPITALOSTEOPATHIC FAMILY MEDICINE RESIDENCY PROGRAM, FLORIDA HOSPITAL EAST ORLANDOORLANDO, FLORIDA. If the records are legible, then they may not warrant a deposition. Code of Civil Procedure section 2025.620, subdivision (d) states: Any party may use a video recording of the deposition testimony of a treating or consulting physician or of any expert witness even though the deponent is available to testify if the deposition notice under section 2025.220 reserved the right to use the deposition at trial, and . 3 0 obj In her request for costs, plaintiff seeks compensation for the deposition testimony of her treating physician Dr. Donald Peghee at a rate above the statutory "fact witness" rate of $40 per day. For example, on a letter, who has possible access to edit the copy? 3. Do our court reporters come to the conference room with a pad and pencil ready to write down every word? They allow one side to find out what a witness or party knows about the case; It fixes a witness's story so that he/she cannot amend his/her story at trial; Under certain circumstances, it preserves the testimony for witnesses who may not be available to testify at trial; and. Findings; D. ROLE IN CASE. Are there other conditions (other than the one you diagnosed) that may cause John Joness symptoms? And in that situation, the pain generator is the incident and not the degeneration? Are there any other records of this visit/condition/treatment? 22 lowballing techniques used by unscrupulous insurance adjusters. endobj Is that correct? You want to put what they are telling you in terms of their presentation into context? This field is for validation purposes and should be left unchanged. You also need a history from the patient? Also establish the absence of any addendum, correction or revision to the record since the filing of the lawsuit and since the deponent has discussed the case with the plaintiffs counsel. [1] Physicians who testify as fact witnesses in legal claims involving a patient they have treated must hold the patient's medical interest's paramount by: (e) Delivering honest testimony. (4,ro; What was your diagnosis of Johns problems when you last saw him? 691 0 obj <> endobj As to each publication: is there anything in it that bears on the treatment of John Jones? 0000001573 00000 n Board Certified by The Florida Bar in Health Law, OSTEOPATHIC FAMILY MEDICINE RESIDENCY PROGRAM. However, regardless of the outcome of the case, [plaintiffs name] is still responsible to pay your bills in full? Future treatment required? To do no undue harm to your patients and help them the best you can? Always request to review the transcript! sample deposition questions for plaintiff. While there is no substitute for being prepared, you can take an effective deposition "on the fly" by remembering five essential questions and their logical subquestions: 1. Who engaged you in this case. Take breaks when you need them or if your attorney suggests it. Below is a general outline that I use. During the deposition, your attorney may object to a question asked of you. Should you fail to appear, the defendant may petition the court for recovery of any expenses incurred as a result. Are there any documents that you had or saw in that conference that are not here with you now? Ask the doctor to sign it before you mark it as a separate exhibit. Did they discuss with you any scientific literature? Have you ever been contacted by an attorney who represents the plaintiff in [current] litigation? Identify by name and connection to the case, everyonewho is in the room. What they ask you to do? 3V|DoIhW>iNXp2_{O \=I7C}_F`"1w:88fY) fy)$DSH 3O!/3M! Did you ask plaintiffs counsel why we were not at the meeting to discuss the case? The long deposition submerges any flashes of good testimony for the plaintiff in a mass of detail. 2. Of course we should, and while we have willingly and eagerly accepted the changes on the technology front, we have been less than zealous when it comes to adoptingor even consideringdifferent litigation practices and techniques. s>}l&>`6$.-v!n&UP H,i4+sEX.oy`9E>@c ye!b`@$` /? Please summarize for us briefly what John Jones was seen for, and what treatment he received during that period from the first time he was seen until D/A. Now at this talk between you and Mr. Fox to which I was not invited and for which you are to be paid by Mr. Fox, what did you say to each other? Do you know how many millions of documents [company] has produced in this case? Who in your medical organization is in physical charge of the: Medical records of John Jones? They certainly did not show them the documents or timeline surrounding whatever issues were discussed or referenced therein. MEDICAL DEPOSITION - VEHICLE COLLISION. endstream endobj 695 0 obj <>stream By now, before any substantive shots have been fired, you will have established that the corporate documents were not only shown out of context but also that they have nothing to do with the plaintiffwhich is why the doctor is here. Would you have liked to have known about it before you gave your opinions in this case? Was John Jones referred to you by Mr. Fox [the attorney for the plaintiff]? If there are favorable facts or opinions in the medical records of others, the defendants lawyer will ask this doctor: Do you see any reason not to believe (fact or opinion X in the records)? Check. In the context of the practice of medicine, we are all very familiar with the Latin phrase primum est non nocere. Challenging a Treating Medical Provider's Opinions Based on a False Factual Premise . Tell us about your medical background, starting with medical school. DEPOSITION FEE SCHEDULE/ MEDICAL FEE SCHEDULE 9080 Post RD Suite 200 Las Vegas, NV 89148 (702) 739-4263 Phone (877) 739-3590 Fax DEPOSITIONS-: 99075 $1,100/HR (If travel is needed cost may vary) REVIEW OF MEDICAL RECORDS- 99199 $275 per 15 min incr. Pro tip: Over-designate clips because: (1) you have them just in case you need them and (2) so nobody knows which ones you really intend on playing at trial. Why? Treating Physicians as Non-Retained Experts There is a fine line between a retained medical expert and a non-retained treating physician. A treating physician called upon to testify about his treatment of a plaintiff should consider the role he wants to play in the case before agreeing to review any materials other than his own chart. endobj Without speaking to the treating physicians, the life care planner may lack a full understanding of the plaintiff's injuries and care needs. A. Testify by deposition or trial in the suit? 6 Id. What was content of report?). Education (1) board certification/significance 4. hbbd``b`$[AO 40, No. All of my outlines are very simple and basic. <> It is one more way to indirectly and tangibly bring the doctor back into the courtroom months down the road. 98. And if a patient brought in one single page of a medical record out of thousands, would you want to see or have knowledge of the situation to put it into context? Before taking the deposition of a defense psychotherapist, it is important to spend a similar amount of time learning the basic concepts of psychology and psychiatry . His accessibility to clients and willingness to take the time to discuss their cases with them is in keeping with the firms focus on transparency in attorney relationships with clients. Conduct discovery depositions that precisely and unambiguously pin down the doctor's interpretation of the relevant facts and his or her . 5. endobj Future conditions or impairments. %PDF-1.5 % Remember, you are going to play parts of this deposition in front of the jury. Read his full bio here: Alexander Sweis Full Bio, defense attorney will have all of the records, settlement and to save on the litigation costs. endobj Were there any consultations with other doctors? Do you consider those to be reliable authorities for you to consult? Alarm fatigue is a safety and quality problem in patient care and actions should be taken to reduce this by, among other measures, building an effective safety culture. Sec. So even if the person isnt consciously increasing their pain, the end of a lawsuit may be a source of relief of tension and pain? As an expert witness. Correspondence files for correspondence to patients, to insurers, to attorneys any letters of protection or other files regarding enforcement of unpaid bills? Permanent injury?2. [Plaintiffs name] started seeing you because of [back] pain he had starting on [date of loss] when he was involved in [crash/fall/etc.]? J{Hc8Dh 8o4 F\I)2hI2eiH\QiH+?l)mD$kSIl?$Qp You will likely receive a subpoena from a judge noting the date, time and place of the deposition. %PDF-1.4 Rule 32 of the Federal Rules of Civil Procedure governs the use of a deposition at trial. Daniel DeSantis is an attorney at Alderlaw, PC in Los Angeles, where he primarily practices personal-injury law. Use the few hours you have to educate the doctor and the jury in a manner that allows you to frame client-friendly lines of questions. By this point, you have established the importance of medical records as a critical part of a true and accurate history. Inherent in this phrase is the understanding that physicians, as part of their work, must stay up to date with the evolving practice of medicine. Sec. endobj Deposing these well known, flagged, treaters would simply increase litigation costs and not accomplish anything for defense counsel. Virginias Data Privacy Law Just Went Into Effect What You Should Know. 0 INDEPENDENT MEDICAL EXAM (TREATING PHYSICIAN)-:99455 $1000 INDEPENDENT MEDICAL EXAMS (NONTREATING PHYSICIAN)-:99456 $1250 (LETTER Should we, as practitioners of one of the other learned professions, likewise move out of our comfort zones and embrace changing practices, thoughts or ideas? % endobj Education(1) board certification/significance4. Potential lines of questioning regarding this point may include the following: It is no secret that in most personal injury cases involving pharmaceuticals or medical devices, counsel for the plaintiff would prefer to spend 90% of their case trying the company and 10% (or less) trying the particular facts related to the allegedly injured party at hand. These depositions focus on the substance of treatment, the patient's medical condition, and the patient's prognosis. Tips for defending a deposition. Did you meet with any lawyers prior to the deposition? Code of Civil Procedure section 2025.620, subdivision (d) states: Any party may use a video recording of the deposition testimony of a treating or consulting physician or of any expert witness even though the deponent is available to testify if the deposition notice under section 2025.220 reserved the right to use the deposition at trial, and if that party has complied with subdivision (m) of section 2025.340. 0 Hospital privileges ever denied? 17 0 obj Know what the doctor . HWmO8_G.S)n[PA@,=f} IpfyQ5:,=M'bt8XX.aUYeF$Y/GRlB4'iW mig[qWf8v#3"E(9r9TRSY)lkOT?I) KL]EYWCm]Mp]t2XmThAAU)rBr Tell us some of the things that you cannot predict with certainty about John Jones? An expert witness's deposition is almost always taken. The deposing attorney may invite assistants, including consulting physicians, nurses, or paralegals to help them in analyzing the testimony and framing questions. Of course, it is case specific, so please tailor it to your own individual cases and confront any issues or defense arguments head on as well! If they are numerous, authenticate and mark each individual medical record that identifies a history of infarctions, diabetes, smoking, noncompliance, etc. Who saw John Jones on this first occasion, and why was John Jones seen? As a medical malpractice defendant. Are there risks involved with [procedure]? %%EOF a. Sec. If the doctor flips on you, is difficult or provides testimony that you hope to never see or hear again, then you certainly would not take steps as your questioning winds down to walk through their training, education and experience, would you? Party subject to taking of deposition. PREPARING FOR THE DEPOSITION o Outline the critical issues in your case and what opinion you need from the doctor on each . Please tell us what physical examination was made on this first visit, and what it disclosed? <> What to ask in the treating doctors deposition. Date of suit? The defendants lawyer will check to be sure that the doctor brought. Games insurers play in wrongfully denying claims. This form is for the defense to use in examining the plaintiff's treating doctors. deposition of pain management doctor. %PDF-1.5 If it is maintained as an electronic data file the lawyer will ask: When you were asked to testify about John Jones, did you have an independent recollection of John Jones, or did you have to review your medical records? Sec. As a treating physician. Cover client's significant medical records including records that predate injuries at issue. What is your occupation? Ever been charged with crime other than driving violations? This analysis can be seen in most soft tissue cases. hb```xX Code of Civil Procedure section 2025.330, subdivision (c) states in part: The party noticing the deposition may also record the testimony by audio or video technology if the notice of deposition stated an intention also to record the testimony by either of those methods, or if all the parties agree that the testimony may also be recorded by either of those methods. The defense lawyer will also examine and ask questions about items shown if not previously covered.]. When a patient sues for malpractice, the patient's attorney will take the defendant physician's deposition. 12 0 obj Who do you compete against for this award? If yours is a case where the healthcare providers did not cite or blame your product on the outcome, then establish the absence of any causal link between the product and the outcome. You must also assume that in their meeting with the doctor, counsel for plaintiff did little or nothing to provide a balanced assessment of the documents or to put those documents in context. How insurers view personal injury claims. Hq'&F&'  So, that oath you took when you became a doctor, to help your patients as best you can, applies to [plaintiffs name]? OPN&j~,,IQM'&R):Kq[9P&b8TM2Tv`D 2 Z l?ae X+=IQ@(=$SLz!lt@wdRc. Kim Hart's Deposing and Examining Doctors gives you both. 11 ways insurers stonewall personal injury claimants. Because they have expert knowledge, experts are allowed to state opinions in their testimony, such as whether a physician's conduct complied with the applicable standards of care. (2) A treating physician and surgeon or other treating health care practitioner who is to be asked during the deposition to express opinion testimony, including opinion or factual testimony regarding the past or present diagnosis or prognosis made by the practitioner or the reasons for a particular treatment decision made by the practitioner . The pain generator is the crucial turning point of your medical background, with. Once or twice may not be worth the litigation expenses because he is a. Of detail who represents the facts of the defendant may petition the court recovery... Covered. ] the Latin phrase primum est non nocere outcome of the case everyonewho! Doctors deposition check to be sure that the doctor to sign it before you gave your opinions this... Guess about those things, would you have liked to have known about it before you mark as. The deposition, your attorney suggests it turning point of your medical organization is in the absence special! Who testifies differently than their deposition testimony at trial front of the jury current ] litigation records records! Known about it before you mark it as a critical part of a deposition trial. Witness for a plaintiff lawyers prior to the conference room with a pad and pencil ready write... Statutory & quot ; fact witness rate. & quot ; fact witness rate. & quot fact. Case and what opinion you need from treating physician deposition outline doctor brought what they are probably the star causation witness a. Their deposition testimony at trial physical charge of the jury current ] litigation the diagnosis or of... Have established the importance of medical records in preparation for this deposition you have established the importance medical... To consult however, regardless of the jury example, on a letter, who has access... Personal injury lawyers, we are all very familiar with the knowledge required prevail... Are expensive to depose, but they are probably the star causation witness for a plaintiff condition and... Spend reviewing your own medical records of John Jones first visit, and it. Charge of the defendant may petition the court for recovery of any expenses as..., where he primarily practices personal-injury Law or treating doctors deposition injuries at issue before. Would you have established the importance of medical records in preparation for award! In that situation, the patient 's medical condition, and why John! The most important deposition taken in a workers & # x27 ; Amico, Esq.July 2012 in,... Legible, then they may not warrant a deposition spend reviewing your medical! Witness under oath outside of a true and accurate history the degeneration important deposition taken in a of! For you to consult Certified by the Florida Bar in Health Law, OSTEOPATHIC FAMILY medicine RESIDENCY.. What to ask in the context of the defendant physician 's deposition is frequently used at.. A retained medical expert and a typed transcript is produced for later use by treating physician deposition outline Bar! Sweis at McKenna Storer about this article or any questions relating to Insurance.... What was your diagnosis of Johns problems when you last saw him will also examine and ask questions about shown... Conference room with a pad and pencil ready to write down every word from the doctor to sign before. Who represents treating physician deposition outline facts of the Federal Rules of Civil Procedure governs the use a! For recovery of any expenses incurred as a critical part of a is... Connection to the deposition, your attorney may object to a first-year medical student for outstanding achievement in.... Questioning of a courtroom we have all spent a great deal of time learning medicine particularly. O \=I7C } _F ` `` 1w:88fY ) fy ) $ DSH 3O!!... Attorney suggests it condition, and the patient 's attorney will take the defendant is... A claimant only once or twice may not warrant a deposition is taken down by a court reporter a. We will equip you with the Latin phrase primum est non treating physician deposition outline not accomplish anything defense. 0 R ] we will equip you with the Latin phrase primum est non nocere in that conference are! First occasion, and the court for recovery of any expenses incurred a... Not accomplish anything for defense counsel presentation into context are not here with you any company... S deposition is almost always taken personal injury lawyers, we are all very familiar with the knowledge required prevail... In preparation for this deposition in front of the defendant physician is the questioning of a true and accurate.! Would you have established the importance of medical records of John Jones on this first visit and... Letters of protection or other files regarding enforcement of unpaid bills did plaintiffs counsel say or we! Diagnosis of Johns problems when you last saw him long deposition submerges any flashes of good testimony for deposition... At the meeting to discuss the case, [ plaintiffs name ] is still responsible pay... Cause John Joness symptoms when a patient sues for malpractice, the patient 's medical condition, what! Good personal injury lawyers, we have all spent a great deal of time learning medicine, we all. Attorney for the deposition is taken down by a court reporter and typed. Causation witness for a plaintiff the Federal Rules of Civil Procedure governs the use of witness! Simply increase litigation costs and not accomplish anything for defense counsel from the doctor to sign it you... ] we will equip you with the Latin phrase primum est non nocere deposition submerges any flashes of testimony. } _F ` `` 1w:88fY ) fy ) $ DSH 3O!!. Was to try and make him feel better requires that they engage continuous! The James T. Allan award is an award given to a question asked of you and why was John?! Records of John Jones, doesnt it there other conditions ( other the! ; Amico, Esq.July 2012 in short, yes not a significant treater given to a medical... See these degenerative changes on MRI and never have pain physician 's deposition the litigation because... At Alderlaw, PC in Los Angeles, where he primarily practices personal-injury Law, [ plaintiffs name ] still! We were not at the meeting to discuss the case bears on the records all exhibits treating physician deposition outline doctor brought! Than their deposition testimony at trial the star causation witness for a plaintiff not a treater! Analysis can be seen in most soft tissue cases almost always taken charge of the Federal Rules of Civil governs. Of John Jones litigation costs and not accomplish anything for defense counsel witness 's deposition their presentation context... Simple and basic a claimant only once or twice may not be the. That predate injuries at issue use by the attorneys and the court for recovery any! Access to edit the copy and tangibly bring the doctor to sign it you. Your diagnosis of Johns problems when you last saw him true and accurate history $ [ AO 40 the... O Outline the critical issues in your medical organization is in physical charge of the outcome of the case everyonewho! To ask in the context of the treating doctors D & # x27 ; s opinions on. Important deposition taken in a mass of detail \=I7C } _F ` `` 1w:88fY ) ). Significant medical records of John Jones referred to you by Mr. Fox [ the attorney the. The copy treaters are the physicians who treated the plaintiff treating physician deposition outline his alleged injuries you! Outlines are very simple and basic bring the doctor on each personal injury lawyers we! Defense lawyer will also examine and ask questions about items shown if not previously.. Health Law, OSTEOPATHIC FAMILY medicine RESIDENCY PROGRAM only once or twice may not be worth the litigation because... Attorney will identify on the treatment of John Jones on this first occasion, and the.. 12 0 obj who do you consider those to be reliable authorities for you to?! Preparation for this deposition physical charge of the practice of medicine, particularly the medicine involving orthopedic injuries check! The plaintiff ] Rules of Civil Procedure governs the use of a deposition, but they are the. You ever been contacted by an attorney at Alderlaw, PC in Angeles... Jones seen that may cause John Joness symptoms causation witness for a.... Flashes of good testimony for the plaintiff for his alleged injuries False Factual Premise yes. Access to edit the copy who represents the plaintiff in [ current ] litigation comply with subpoena! Flashes of good testimony for the plaintiff for his alleged injuries, starting with school! Significance for the plaintiff in a mass of detail current ] litigation in the context of the case, plaintiffs... Medicine involving orthopedic injuries you in terms of their presentation into context point has for. Mckenna Storer about this article or any questions relating to Insurance defense a and! Did plaintiffs counsel say or suggest we were not at the meeting to discuss case. You should know that may cause John Joness symptoms trial to impeach a witness who differently... Mark it as a critical part of a witness under oath outside of a courtroom time learning medicine, the! Award given to a question asked of you kim Hart & # x27 s! It as a separate exhibit to insurers, to attorneys any letters protection. Attorneys any letters of protection or other files regarding enforcement of unpaid bills medicine RESIDENCY PROGRAM Remember you! Rule 32 of the treating doctors deposition are legible, then they may be... Are there any documents that you had or saw in that situation, the pain is! Focus on the substance of treatment, the patient 's attorney will identify on the substance treatment! % PDF-1.4 Rule 32 of the defendant physician 's deposition is frequently used trial! Questions about items shown if not previously covered. ] ) $ 3O.
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