The Direct Examination of the Plaintiff's Treating Physician

Index

• Caveat to Lawyers
• Caveat to Members of the Public
• About the Authors
• Table of Contents
• I Introduction
• II Purposes of Direct Examination of Plaintiff's Doctor
• III Using the Client's Statements to the Treating Physician Made for Purposes of Treatment and Diagnosis
• IV Countering the "pre-existing Condition" Defense - Ill. R. Evid. 803(7)
• V Questions Intended to Show the Absence of Medical Evidence of Pre-existing Condition Utilizing Ill. R. Evid. 803(7)
• VI Presenting Expert Opinions Based Upon Facts or Data Perceived by the Physician before Trial: Wilson V. Clark and Ill. R. Evid. 703
• VII Disclosing the Expert Witness
• VIII Preparing the Treating Physician for Discovery Deposition Testimony
• IX When Plaintiff May Wish to Take Treating Physician's Discovery Deposition
• X Preparation for Evidence Deposition/trial Testimony
• XI Creating the Outline
• XII Transitional Questions
• XIII Using the Language of the Jury Instructions
• XIV Refreshing Recollection
• XV Anatomical Models
• XVI Learning the Science
• XVII Conclusion