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- Texas Employment Law. Volume 2 - 2017
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- Trial
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
...To continue reading
Request your trial- Appendices
- Trial
- Defendant's limine motion in employment cases in general (fed)
- Juror questionnaire for use by defendant in employment case (state and federal)
- Unopposed/opposed motion and brief for use of juror questionnaire (state & fed)
- Order granting use of juror questionnaire (state & fed)
- Direct Examination Outline: Defendant's H.R. Manager
- Direct examination outline: plaintiff's economist in employment (and personal injury) cases
- Trial brief: evidence of similar incidents is relevant and admissible
- Plaintiff's limine motion in employment cases in general (state)
- Defendant's limine motion for employment cases involving AGE/RACE (FED)
- Plaintiff's Jury Instructions and Jury Charge: Whistleblower Case (State Court)
- Defendant's Proposed Questions and Instructions to the Jury and Memorandum of Law: Age (Reduction In Force) and Race Discrimination Case (Federal Court)
- Defendant's proposed voir dire questions for judge in age, race & rif cases (fed & state)
- Defendant's Proposed Voir Dire: Age, Race (Fed.)
- Defendant's Trial Brief: F.I., Breach of Contract, Handbook, Mitigation
- Stipulation: Plaintiff's Damages
- Stipulation: plaintiff's reasonable & necessary attorney's fees
- Stipulation: corporation assumes liability, if any, for subsidiary or related companies in dispute involving current or former employee (state/federal)
- Direct: Treating Psychologist For Plaintiff
- Order on motion to strike witnesses and objections to fact witnesses (fed)
- Brief in support of motion to strike and objections to testimony of fact witnesses (FED)
- Motion to Strike Witnesses
- Juror Personal History Questionnaire
- Defendant's jury instructions & questions: sex discrimination, retaliation and FLSA violations (fed.)
- Sample Jury Charge-Non-Compete Case
- Defendant's requested jury instructions and written interrogatories
- Juror Questionnaire - Gender Discrimination and Breach of Contract
- Plaintiff's Jury Demand
- Plaintiff's Motion in Limine - Gender Discrimination Case - State Court
- Plaintiff's Requested Jury Instructions and Questions - Gender Discrimination and Breach of Contract
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