Deposition of the Plastic Surgeon

• Author: Kim Patrick Hart
• Pages: 425-435

23-1

Chapter 23

Deposition of the Plastic Surgeon

I. INTRODUCTION

§23:01 Plastic Surgeons Make Good Witnesses

§23:02 It’s all About the Future, Baby!

§23:03 Selecting a Plastic Surgeon

II. PRE-SUIT CONTACT WITH THE TREATING PLASTIC SURGEON

§23:10 Referral of Client to Plastic Surgeon

§23:11 Plastic Surgeon’s Affidavit

§23:12 Every Picture Tells a Story, Don’t It?

III. PREPARING TREATING PLASTIC SURGEON FOR DEPOSITION

§23:20 Meetings

§23:21 Crucial Issues in Scarring Cases

§23:22 Nail Down Crucial Issues

§23:23 Countering Defense Tactics

§23:24 First Tactic: Client Not Interested in Plastic Surgery

§23:25 Second Tactic: Others Involved in Case Live with Worse Scars

§23:26 Third Tactic for Auto Crashes: Seat Belt Would Have Prevented Scars

IV. PREPARING CLIENT FOR THE COMPULSORY MEDICAL EXAMINATION BY DEFENSE PLASTIC SURGEON

§23:40 Defense Often Does Not Use a Plastic Surgeon

§23:41 Use of Make-Up

§23:42 Desire for Revision

§23:43 Impact of Scar on Client

§23:44 Dealing with Other Scars

V. PREPARING FOR DEPOSITION OF DEFENSE PLASTIC SURGEON

§23:50 Request List of Prior Cases

§23:51 Request Photos

§23:52 Other Information Sources

§23:53 Medical Records

§23:54 Review CME Report

§23:55 Outline of the Defense Deposition

VI. SAMPLE DEPOSITION OF THE DEFENSE PLASTIC SURGEON (DOG BITE CASE)

§23:60 Background and Training

§23:61 Identification of Books, Professional Journals, and Informational Material Available to Patients and

Acknowledgment of Authoritative Status

§23:62 Positive Points Acknowledged

§23:63 Points of Disagreement

§23:64 Review of All Previous Testimony

§23:65 Previous Experience Working as a Compulsory Medical Examiner

§23:66 Website

VII. FORMS

Form 23:10 Plastic Surgeon’s Pre-Suit Affidavit

Form 23:20 Subpoena Duces Tecum for Deposition of Plastic Surgeon