Direct: treating psychologist for plaintiff

PLAINTIFFS' TREATING PSYCHOLOGIST

INTRODUCTION

Name

Where were you born

Age

EDUCATION

Where did you go to high school

What did you do after high school

Did you get a degree

What did you do after getting your degree

Have you received any higher degrees

Have you published any papers

Have you given any seminars

Experience with ________ psychology

How many graduate level courses did you have in child and adolescent development

How many years did you treat ________________in the [medical care provider]

What was your caseload

Did you do a residency

Where

While doing your residency did you treat _________

What experience for treating ___________________ here in _______?

What was your title

Duties as ____________________

Did you supervise other psychologists.

How long were you chief of the ________________ program

Were you on the staff of any hospital where you treated children

Did you have other experience at that clinic

TREATMENT OF ______________

How many ____________ treated for psychological problems over the years

Are you on the staff of any hospital

EVALUATION OF _________

How many children do you evaluate per year to determine if need counseling

VOLUNTEER WORK

CHARGES

Dr. _________, what do you charge per hour

Why do you charge so much more for testifying/treating

*Don't like testifying

How often do you testify

How many times have you testified in court

How many depositions have you given

When was the last time you testified

DESCRIBE GRIEF

What is the worst kind of grief that a person can suffer

TREATMENT OF PLAINTIFFS

Have you had occasion to meet ____________________

When did you first meet them

What was the purpose of meeting with the Plaintiffs

* Evaluate need for counseling

STANDARD EVALUATION

Please tell me what takes place in the standard evaluation

* Learn about what happened

* Learned what the patient saw

Why is it important to know what the patient saw

* Develop context of grief

What do you do after you learn what happened

* Evaluate the level of their depression

How do you do that

* Ask questions about appetite

* Irritability

* Fatigue

* Sleeplessness

* Examine intensity of their feelings

EVALUATION OF PLAINTIFFS

What did the Plaintiffs tell you during their evaluation

What were the Plaintiffs feeling

* Pain

* Anger

* Grief

Can you remember all of what they told you

Did you take notes

Would you read your notes please

Were these feelings having any effects on the Plaintiffs

* Depression

...