How to prepare for a treating physician's deposition

Lawyers’ Forum

By Thomas N. Osran

Thomas N. Osran is a senior assistant general counsel at the Chicago Housing Authority. He may reached via email at thomasnosran@gmail.com.

Posted November 19, 2019 3:30 PM

In my last column, I discussed how to depose a treating physician, or treater. But to take a good deposition of such a physician or other professional, I noted that you need to prepare for it. This column will explore that.And it starts long before you send out the treater’s subpoena.What to get in written discoveryFirst, it begins with the written discovery questions you send to the plaintiff.Have they had any prior injuries? At any time? What is their pre-existing condition prior to the accident? You need to …

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