Deposition outline-medical/mental health professional
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BACKGROUND AND PRELIMINARY QUESTIONS
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Identifying Information
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Full name, address and telephone number.
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Driver’s license and Social Security number for background investigation.
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Description of profession and job title.
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Identify current employer including address and telephone number and length of employment.
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Education History (obtain a resume if available)
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Identify education and professional training.
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Degrees, certificates or professional certification and licensor.
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Confirm dates of certification or licensure and where obtained.
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Describe the significance of each certification and what type of practice it allows.
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Have any of the experts’ certifications or licensors been suspended, revoked or limited?
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Any on-the-job training or employer-related training or certification.
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Honors or appointments.
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Published Writings
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Identify all publications (focus on any published writings or works related to the subject matter of a lawsuit).
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If expert’s resume not available or does not contain published works, detail each publication, date published, where published, co-authors and availability of copies.
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Research
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Identify all research, focusing on research related to the subject matter lawsuit.
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Identify collaborators and institutions or sponsoring entities.
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Identify all writings or publications of research results and analysis.
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Determine availability of written documentation of research conducted.
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Employment History
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Identify each employer (focus on employment history related to expert’s subject area).
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Identify time periods of employment, positions and job titles.
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Describe capacity of employment with each employer including responsibilities and functions.
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Determine the reason for each change of employment.
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State whether witness has ever been suspended, terminated, disciplined or sanctioned by any employer.
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Verify total percentage or length of time during professional career related/not related to subject matter of witness’s opinions in the case.
Describe the nature of your professional practice.
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Describe the types of therapy or treatment rendered in practice.
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Describe the types of patients treated (eg. children, adults, general family practice, etc.).
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Explore any limitations to the witness’s practice (i.e. if the witness is not a psychiatrist, they can’t prescribe drugs, their certification may impose limits on what they can do and who they can treat).
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Explore the types of testing the witness is trained in administering and the types of testing the witness is not trained in administering.
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Professional Organizations and Affiliations
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Identify each professional organization to which witness belongs.
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Focus on organizations related to subject matter in lawsuit and determine criteria for membership and status of membership.
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Review resume and question witness regarding any affiliations with organizations which may be controversial, discredited or a spouse positions adverse to the opinions of the witness.
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Determine whether witness’s membership in an organization has ever been suspended, terminated or scrutinized.
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Identify any leadership positions held in any organizations.
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Litigation
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Prior deposition testimony.
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Prior trial testimony.
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Identify each instance in which expert has been retained to give testimony (include identification of names of parties, names of attorneys, location of lawsuit, etc.).
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Identify and discuss each instance where expert addressed similar issues to subject matter of case in question.
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Determine in each instance whether the witness was retained by the plaintiff or the defense.
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Is the expert aware of any instance where his/her testimony has been struck or limited by a judge?
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Does the witness maintain copies of any deposition transcripts or written reports?
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Does the witness maintain a list of prior litigation?
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What percentage of expert’s yearly income is derived from litigation/consulting work?
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Does the witness advertise his/her services?
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Does the witness belong to any referral services or networks?
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Has the witness ever been a party to a lawsuit? (If yes, obtain details.)
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Does the witness belong to any organizations...
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