IX When Plaintiff May Wish to Take Treating Physician's Discovery Deposition

• Library: The Direct Examination of the Plaintiff's Treating Physician (2017 Ed.)

IX. WHEN PLAINTIFF MAY WISH TO TAKE TREATING PHYSICIAN'S DISCOVERY DEPOSITION

Typically, during the course of written discovery, plaintiff's counsel will receive interrogatories seeking the identification of all medical professionals who have treated plaintiff. Also, the defense will make requests to produce documents including all the medical records relating to the treatment and any opinions plaintiff expects will be expressed by the treater. Plaintiff's counsel will make every effort to disclose "all" of the opinions as that is the requirement of Ill. S. Ct. R. 213. However, often when such responses to interrogatories are conveyed to defense counsel, you...